United States v. Sergeant EDWARD T. MCTEAR

CourtArmy Court of Criminal Appeals
DecidedSeptember 23, 2024
Docket20220531
StatusUnpublished

This text of United States v. Sergeant EDWARD T. MCTEAR (United States v. Sergeant EDWARD T. MCTEAR) is published on Counsel Stack Legal Research, covering Army 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. Sergeant EDWARD T. MCTEAR, (acca 2024).

Opinion

UNITED STATES ARMY COURT OF CRIMINAL APPEALS

Before FLEMING, PENLAND, and COOPER Appellate Military Judges

UNITED STATES, Appellee v. Sergeant EDWARD T. MCTEAR United States Army, Appellant

ARMY 20220531

Headquarters, Fort Stewart Albert G. Courie III and Trevor I. Barna, Military Judges Colonel Joseph M. Fairfield, Staff Judge Advocate

For Appellant: Colonel Phillip M. Staten, JA; Lieutenant Colonel Autumn R. Porter, JA; Major Robert D. Luyties, JA; Captain Amber L. Bunch, JA (on brief).

For Appellee: Major Patrick S. Barr, JA; Major Chase C. Cleveland, JA; Major Kathryn M. Moryl, JA (on brief).

23 September 2024

This opinion is issued as an unpublished opinion and, as such, does not serve as precedent.

COOPER, Judge:

Appellant raises three assignments of error, one of which merits discussion but no relief.' At the heart of this assignment of error are three recordings which were never provided to defense counsel. Appellant alleges the government violated appellant’s discovery rights by failing to provide the videos that may have contained relevant and exculpatory evidence. We disagree.

' We have reviewed the issues raised by appellant pursuant to United States v. Grostefon, 12 M.J. 431 (C.M.A. 1982) and find that they do not merit relief. MCTEAR — ARMY 20220531 BACKGROUND

A military judge sitting as a general court-martial convicted appellant, contrary to his pleas, of one specification of sexual assault and two specifications of abusive sexual contact, in violation of Article 120, Uniform Code of Military Justice, 10 U.S.C. § 920 (2019) [UCMJ]. The military judge found appellant not — guilty of attempted sexual assault, in violation of Article 80, UCMJ.?_ The military judge sentenced appellant to a dishonorable discharge, 24 months of confinement, reduction to the grade of E-1, and total forfeitures.

In the fall of 2020, appellant met the victim in the stairway of the apartment complex where they both lived. They developed a friendship and began hanging out a couple of times a month. On 9 January 2021, appellant invited the victim to a housewarming party at his new apartment. The victim arrived at 2200 hours and she had a couple of shots, two to three mixed drinks, a beer, and smoked marijuana. Feeling “super drunk,” the victim began to get tired and sick. She vomited in the kitchen sink, and friends at the party moved her to the bathroom. She vomited again in the bathroom and appellant lifted her up from the floor and carried her into the guest bedroom. He left her in the bedroom with a glass of water and a trash can in case she threw up again.

The victim fell asleep and the next thing she remembered was appellant getting into the bed with her. She told him to go to a different bed. The victim woke up again to appellant touching her back and her buttocks. She swatted him away and told him to stop. The next thing the victim remembered was feeling (1) her pants unbuttoned and unzipped, (2) wetness in her vagina and buttocks, and (3) appellant’s penis leaving her vagina. She pushed him away and ran into the bathroom. After cleaning herself up, she went to her car and called a friend for assistance. The same morning, she was examined by a Sexual Assault Nurse Examiner (SANE) at a rape crisis center.

Later that same day, a friend of the victim, went to appellant’s house with three to four other men. BB confronted appellant and asked him if he raped the victim. Appellant denied it and a fight ensued between the two men. The physical altercation lasted under a minute and the group left appellant’s house.

A. Party Video

recorded the first video at appellant’s house party hours before the sexual assault. testified the video showed a “pretty intoxicated” appellant stripping to

? Following a motion from defense counsel on unreasonable multiplication of charges, the military judge conditionally dismissed the two abusive sexual contact specifications and moved forward to presentencing with the sole remaining sexual assault offense. MCTEAR ~— ARMY 20220531

(CID) and there is no evidence either party knew about it beforefM’s trial testimony. Defense counsel did not object to references to this video, did not ask any questions about it on cross-examination, and did not request production of the video. There was no further reference to this video, and it was not admitted into evidence.

his underwear. This video was not provided to Criminal Before s Division

B. Confrontation Video

i recorded this video outside of appellant’s house the morning after the sexual assault. BM testified:

Me and a group of friends went to Sergeant McTear’s house, went into his house, pulled him off the couch. I told him to step outside. I pulled out my phone to record and asked him — or told him that [victim] told me that he raped her.

Defense counsel asked ff about the video, and confirmed he deleted it right after he left appellant’s house that day.

On redirect, BB clarified that appellant had no verbal responses on this video, so he stopped recording. “I asked him a couple times, ‘Did you rape her? Did you rape her?’ And he just kind of sat there, so I stopped recording.”

As with its predecessor, apparently neither party knew about this video until a testified. Defense counsel neither objected to this testimony nor requested production of the Confrontation Video.

C. Fight Video

rs friend recorded the third video outside appellant’s house, capturing a fight between fi and appellant. The day before trial, MM showed this video to the trial counsel but refused to provide a copy. Trial counsel notified defense of the video the same day.

During trial, it became apparent there was confusion concerning the fact that there were two videos taken outside of appellant’s home - the Confrontation Video and the Fight Video. When trial counsel asked {J about the Fight Video and confirmed it still existed, defense objected under the best evidence rule. During the subsequent Article 39(a), UCMJ session, the trial counsel described what he observed in the video: “the accused and the witness are fighting. There is nothing exchanged. It’s clearly the accused and the witness in the video” and “nothing was even said.” MCTEAR — ARMY 20220531

The military judge subsequently determined the Fight Video was not relevant and it was never produced or admitted at trial. Defense voiced no further objections concerning the three videos during the trial. No defense discovery request appears in the record of trial and, now before this court, appellant does not point us to one.

LAW AND DISCUSSION

The Due Process Clause of the Fifth Amendment requires the prosecution to disclose evidence that is material and favorable to the defense. United States v. Brady, 373 U.S. 83, 87 (1963). This is so whether there is a general discovery request from defense or no request at all. United States v. Agurs, 427 U.S. 97, 107 (1976). The government commits a discovery violation when it “withholds evidence that is favorable to the defense and material to the defendant’s guilt or punishment.” United States v. Behenna, 71 M.J. 228, 237-38 (C.A.A.F. 2012) (citing Smith v. Cain, 565 U.S. 73, 75 (2012)). Favorable evidence is “exculpatory, substantive evidence or evidence capable of impeaching the government’s case.” Jd. at 238 (internal citations omitted).

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
United States v. Agurs
427 U.S. 97 (Supreme Court, 1976)
Arizona v. Youngblood
488 U.S. 51 (Supreme Court, 1989)
Kyles v. Whitley
514 U.S. 419 (Supreme Court, 1995)
Smith v. Cain
132 S. Ct. 627 (Supreme Court, 2012)
United States v. Behenna
71 M.J. 228 (Court of Appeals for the Armed Forces, 2012)
United States v. Simmermacher
74 M.J. 196 (Court of Appeals for the Armed Forces, 2015)
United States v. Stellato
74 M.J. 473 (Court of Appeals for the Armed Forces, 2015)
United States v. Williams
50 M.J. 436 (Court of Appeals for the Armed Forces, 1999)
United States v. Grostefon
12 M.J. 431 (United States Court of Military Appeals, 1982)

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United States v. Sergeant EDWARD T. MCTEAR, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-sergeant-edward-t-mctear-acca-2024.