United States v. Schnitzer

44 M.J. 380, 1996 CAAF LEXIS 47, 1996 WL 640630
CourtCourt of Appeals for the Armed Forces
DecidedAugust 30, 1996
DocketNo. 95-5001; Crim.App. No. 9202662
StatusPublished
Cited by10 cases

This text of 44 M.J. 380 (United States v. Schnitzer) is published on Counsel Stack Legal Research, covering Court of Appeals for the Armed Forces primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Schnitzer, 44 M.J. 380, 1996 CAAF LEXIS 47, 1996 WL 640630 (Ark. 1996).

Opinions

Opinion of the Court

SULLIVAN, Judge:

During December of 1992, the accused was tried by a general court martial composed of officer and enlisted members at Vilseck, Germany. Entering mixed pleas, he was found guilty of attempted premeditated murder; violation of a lawful general regulation (wrongful possession of drug paraphernalia); wrongful possession of marijuana; rape (2 specifications); forcible oral and anal sodomy, and kidnapping,1 in violation of Articles 80, 92,112a, 120,125, and 134, Uniform Code of Military Justice, 10 USC §§ 880, 892, 912a, 920, 925, and 934, respectively. He was sentenced to a dishonorable discharge, confinement for 29 years, total forfeitures, and reduction to pay grade E-l. The convening authority approved this sentence on February 17, 1993. On September 19, 1994, the then-Court of Military Review affirmed the findings but set aside the sentence and authorized a rehearing. On November 2, 1994, the now-Court of Criminal Appeals,2 on reconsideration, reached the same result. 41 MJ 603.

On November 28, 1994, the Judge Advocate General of the Army forwarded the following issues to this Court for review pursuant to Article 67(a)(2), UCMJ, 10 USC § 867(a)(2) (1989). He asked:

I
WHETHER THE MILITARY JUDGE HAS A SUA SPONTE DUTY TO GIVE A LIMITING INSTRUCTION, OVER AP-PELL[EE]’S TRIAL DEFENSE COUNSEL’S AFFIRMATIVE, DELIBERATE, AND CONSCIOUSLY DESIGNED OBJECTION, WHEN A COACTOR’S PRETRIAL AGREEMENT SENTENCE LIMITATION HAS BEEN PROPERLY ADMITTED DURING FINDINGS TO DEMONSTRATE BIAS OR TO REHABILITATE AN IMPEACHED WITNESS.
II
WHETHER THE ARMY COURT ERRONEOUSLY FOUND PLAIN ERROR WHEN APPELL[EE]’S TRIAL DEFENSE COUNSEL AFFIRMATIVELY, DELIBERATELY, AND CONSCIOUSLY OBJECTED TO AND WAIVED HIS RIGHT TO A LIMITING INSTRUCTION REGARDING THE COURT-MARTIAL PANEL’S USE DURING SENTENCING OF PROPERLY ADMITTED EVIDENCE OF BIAS AND WITNESS REHABILITATION IN THE FORM OF A COACTOR’S PRETRIAL AGREEMENT SENTENCE LIMITATION.

We hold that no plain error occurred under the circumstances of this case. Cf. United States v. Kirkpatrick, 33 MJ 132 (CMA 1991) (plain error for military judge to instruct members to consider service drug policy). The failure of the military judge to instruct the members not to consider evidence of a coactor’s pretrial agreement in determining the accused’s punishment was not “clear or obvious” error prejudicial to his substantial rights. See United States v. Kropf, 39 MJ 107 (CMA 1994); cf. United States v. Grady, 15 MJ 275 (CMA 1983) (plain error for military judge to fail to give limiting instruction on obvious command-policy reference); see [382]*382generally United States v. Prevatte, 40 MJ 396 (CMA 1994).

Schnitzer was charged with and found guilty of committing a number of brutal and heinous crimes with a coactor against IR, a German National female. The facts and circumstances surrounding the certified issues were noted by the Court of Criminal Appeals as follows:

During the government’s case in chief, the trial counsel introduced evidence concerning SPC [Specialist] Campbell [the accused’s eoactor]’s pretrial agreement, including the convening authority’s sentence limitation. In an apparent attempt to preempt the defense on the issues of SPC Campbell’s credibility and bias, the trial counsel entered into the following exchange with SPC Campbell.
Q. [...] When you pled guilty at your court-martial were you pleading guilty also to the crimes that involved Specialist Schnitzer?
A. Yes, ma’am. The rape and assault and oral sodomy, kidnapping.
Q. Okay. Was that pursuant to a pretrial agreement? Was that with a pretrial agreement?
A. Yes, ma’am, I had one.
Q. And, how many years did you have in that pretrial agreement? What was your deal for?
A. If I remember correctly, it was for 28 years.
Q. And, what did you receive at your court-martial?
A. I received a 15 year sentence.

41 MJ at 605.

The civilian defense counsel failed to object to this line of questioning and in fact asked SPC Campbell if he was not testifying in the hope of getting a reduction in his “15-year sentence.” Also the military judge did not give an appropriate limiting instruction to preclude the members from considering this evidence for any purpose other than assessing bias.

The Court of Criminal Appeals in its original opinion commented on these facts as follows:

Rule for Courts-Martial 1001(g) [hereinafter RCM] reflects the United States Court of Military Appeal’s [sic] concern over a convening authority’s improper influence over panel members during sentencing deliberations. Under RCM 1001(g), a trial counsel may not, in a sentencing argument, “purport to speak for the convening authority or any higher authority, or refer to the views of such authorities, or any policy directive relative to punishment.”
We believe, however, Grady [United States v. Grady, 15 MJ 275 (CMA 1983)] is broader than RCM 1001(g)’s condemnation of improper trial counsel argument. We find that, in this case, placing before the panel the exact sentence limitation terms of this eoaetor’s pretrial agreement with the convening authority — at any time in a court martial — amounts to placing before the panel the views of that official as to an “appropriate” sentence. This action improperly affects the panel with a powerful external influence. We hold, therefore, that reference before a panel to a specific sentence limitation agreed to by a convening authority in a coactor’s case, absent a limiting instruction, improperly invades the panel’s sentence deliberations, and is error.

Unpub. op. at 5-6 (footnote and citations omitted).

Finally, the record of trial reveals that prior to sentencing deliberations, trial counsel made a request for an appropriate instruction on this evidence.3 At this point the following exchange occurred:

[383]*383MJ: Mr. Bellen [civilian defense counsel], is there any objection to the Government’s proposed instruction?
CDC: Yes, Your Honor. I believe what’s contained in that proposed instruction is contained actually in your standard instruction. By givfing] that, you would unnecessarily highlight the Government’s point. They certainly may argue.
MJ: I will not give the Government’s proposed instruction. Are there any additional requests for instruction by either counsel?
ATC: No, sir.
MJ: By defense?
CDC: No, Your Honor.

The members of the accused’s court-martial subsequently sentenced him, inter alia, to 29 years’ confinement.

It is widely recognized that the codal prohibition against unlawful command influence (Art. 37(a), UCMJ, 10 USC § 837(a)) is a critical safeguard in our modern military justice system. See Weiss v. United States,

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Davis
65 M.J. 749 (Navy-Marine Corps Court of Criminal Appeals, 2007)
Schnitzer, Jeffrey v. White, Thomas E.
389 F.3d 200 (D.C. Circuit, 2004)
United States v. Sills
56 M.J. 556 (Air Force Court of Criminal Appeals, 2001)
United States v. Dinges
55 M.J. 308 (Court of Appeals for the Armed Forces, 2001)
United States v. Eggen
51 M.J. 159 (Court of Appeals for the Armed Forces, 1999)
United States v. Anderson
51 M.J. 145 (Court of Appeals for the Armed Forces, 1999)
United States v. Carter
45 M.J. 168 (Court of Appeals for the Armed Forces, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
44 M.J. 380, 1996 CAAF LEXIS 47, 1996 WL 640630, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-schnitzer-armfor-1996.