United States v. SANTIAGO

CourtNavy-Marine Corps Court of Criminal Appeals
DecidedFebruary 27, 2026
Docket202400399
StatusPublished

This text of United States v. SANTIAGO (United States v. SANTIAGO) is published on Counsel Stack Legal Research, covering Navy-Marine Corps Court of Criminal Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. SANTIAGO, (N.M. 2026).

Opinion

This opinion is subject to administrative correction before final disposition.

Before DALY, GROSS, and de GROOT Appellate Military Judges

_________________________

UNITED STATES Appellee

v.

Jesus S. SANTIAGO Master-at-Arms Second Class Petty Officer (E-5), U.S. Navy Appellant

No. 202400399

Decided: 27 February 2026

Appeal from the United States Navy-Marine Corps Trial Judiciary

Military Judge: Philip J. Hamon

Sentence adjudged 31 July 2024 by a special court-martial tried at Na- val Base San Diego, California, consisting of a military judge sitting alone. Sentence in the Entry of Judgment: reduction to E-1 and forfei- ture of $1,008.60 pay per month for 6 months.

For Appellant: Stephen H. Carpenter, Jr., Esq. Captain Katherine Malcolm, USMC

For Appellee: Lieutenant Erin H. Bourneuf, JAGC, USN Major Mary Claire Finnen, USMC United States v. Santiago, NMCCA No. 202400399 Opinion of the Court

[This opinion does not serve as binding precedent, but may be cited as persuasive authority under NMCCA Rule of Appellate Procedure 30.2.]

PER CURIAM: Appellant was charged with one specification of impersonating an official and four specifications of false official statement, in violation of Articles 106 and 107, Uniform Code of Military Justice (UCMJ). 1 The charges stemmed from allegations he impersonated a congressional liaison, submitted fake let- ters, and made false official statements. Appellant pleaded guilty in accordance with a plea agreement to two specifications of making false official statements to law enforcement. Appellant asserts one assignment of error (AOE) that we rephrase: Did Trial Defense Counsel (TDC) render ineffective assistance by advising and/or permitting Appellant to plead guilty to multiplicious specifications in violation of the prohibition against double jeopardy? We find no prejudicial error and affirm.

I. BACKGROUND

Prior to trial, Appellant moved to dismiss a specification for unreasonable multiplication of charges. 2 The military judge denied the motion to dismiss at the time, however, the military judge told the parties he would readdress the issue once findings were announced. 3 Later, Appellant entered into a plea agreement to plead guilty to Specifica- tions 3 and 4, of Charge II, with certain exceptions and substitutions. Specification 3: In that [Appellant,] . . . did, at or near Chicago, Illinois, on or about 9 February 2019, with intent to deceive, make to [Naval Criminal Investigative Service (NCIS) agents], an official statement, to wit: that the letter from Douglas Taylor

1 10 U.S.C. §§ 906, 907.

2 App. Ex. XI. The motion was for an unreasonable multiplication of charges with

a specification and charge no longer before the court based on the plea agreement. 3 R. at 106.

2 United States v. Santiago, NMCCA No. 202400399 Opinion of the Court

dated 3 January 2019 was authentic, or words to that effect, which statement was totally false, and was then known by [Ap- pellant] to be false. Specification 4 (as excepted and substituted): In that [Appel- lant,] . . . did, at or near Chicago, Illinois, on or about 9 February 2019, with intent to deceive, make to [NCIS agents], an official statement, to wit: that I received a letter in the mail purporting to be from Douglas Taylor with a recommendation to the board that I not be held liable to my debt, or words to that effect, which statement was totally false, and was then known by [Appellant] to be false. Appellant agreed to plead guilty to these two specifications of false official statement in exchange for the Government dismissing the remaining specifi- cations and other charge. The parties also agreed that no punitive discharge, confinement, fine, or other lawful punishments would be adjudged, but Appel- lant would receive forfeiture of one-half pay per month for 6 months and re- duction to E-1. In a stipulation of fact, Appellant admitted that he was asked about the authenticity of a letter purporting to be from Douglas Taylor, Congressional Liaison, Assistant Secretary of the Navy (Manpower and Reserve Affairs), and told NCIS agents that it was authentic when he knew it to be false because he wrote and signed the letter. 4 When asked how he came into possession of a letter, he told NCIS agents that he “received the letter in the mail and that it was a recommendation that would be provided to the board that” he not be held liable for his debt. 5 After the Court was assembled, and prior to taking Appellant’s pleas, the military judge advised Appellant that he should make any motion to dismiss or to grant other appropriate relief. 6 Trial Defense Counsel raised no motions and entered pleas on behalf of Appellant in accordance with the plea agree- ment. 7 Appellant admitted to committing the two false official statements and agreed that his counsel had correctly stated his pleas. Additionally, the military judge went over the provisions of the plea agree- ment with Appellant, including the agreement to waive all motions except

4 Pros. Ex. 1 at 2.

5 Pros. Ex. 1 at 3.

6 R. at 157.

7 R. at 158.

3 United States v. Santiago, NMCCA No. 202400399 Opinion of the Court

those that are non-waivable. 8 The military judge specifically said, “if there is a motion that has been filed that--that now you’ve agreed to waive and so the court has not ruled on that motion, or if there is any motion that you would have filed that you want to put on the record, you may do so.” 9 Trial Defense Counsel responded that he had filed an unreasonable multiplication of charges motion that had not been ruled upon and also that he had considered, but did not file, a multiplicity motion. 10 The military judge expressed skepticism that a motion to dismiss for mul- tiplicity was waivable but wanted to hear TDC’s position. Trial Defense Coun- sel stated, “We are not making any further motions on that, and I may have confused multiplicity with unreasonable multiplication of charges as well, but we -- the point is that the defense is not making those motions.” 11 The military judge continued with Appellant to ensure he knew what motions he was waiv- ing and that it would prevent him from considering it and the appellate court from making a determination on that motion in the future. 12 At the end of the inquiry, Appellant still wished to waive all waivable motions. 13 On appeal, Appellant argues that TDC was ineffective for failing to make a motion to dismiss one of the specifications of which he pleaded guilty on the grounds that a conviction for both specifications violated the Double Jeopardy Clause of the Fifth Amendment.

II. DISCUSSION

A. Standard of Review and Applicable Law We conduct a de novo review of ineffective assistance counsel claims. 14 When evaluating claims of ineffective assistance of counsel, this Court applies

8 R. at 188.

9 R. at 189.

10 R. at 189.

11 R. at 190.

12 R. at 191.

13 R. at 192.

14 United States v. Carter, 79 M.J. 478, 480 (C.A.A.F. 2020) (citing United States v.

Bradley, 71 M.J. 13, 16 (CA.A.F. 2012)).

4 United States v. Santiago, NMCCA No. 202400399 Opinion of the Court

the framework from Strickland v. Washington. 15 Under Strickland, an appel- lant bears the burden of demonstrating that (a) defense counsel’s performance was deficient, and (b) this deficient performance was prejudicial.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
United States v. Rose
71 M.J. 138 (Court of Appeals for the Armed Forces, 2012)
United States v. Bradley
71 M.J. 13 (Court of Appeals for the Armed Forces, 2012)

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