United States v. Sewell

1 M.J. 630, 1975 CMR LEXIS 715
CourtU.S. Army Court of Military Review
DecidedOctober 9, 1975
DocketCM 432204
StatusPublished

This text of 1 M.J. 630 (United States v. Sewell) is published on Counsel Stack Legal Research, covering U.S. Army Court of Military Review primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Sewell, 1 M.J. 630, 1975 CMR LEXIS 715 (usarmymilrev 1975).

Opinion

OPINION OF THE COURT

MOUNTS, Judge:

CASE SUMMARY

Due to the accused’s absence after arraignment a plea of not guilty was entered by the military judge for the accused. The accused was convicted of four specifications of absence without leave. Three of the absences occurred prior to the accused’s pretrial confinement on 23 January 1969. The accused was released from pretrial confinement on 24 January 1969 and was placed in the custody of a county police detective on civilian charges of murder, robbery, burglary, larceny and conspiracy. The release to civil authorities was made pursuant to an agreement that the civil authorities would inform the military of the outcome of the trial or any other disposition of the charges and return the accused to the military, upon disposition of his case or when custody by civil authorities was no longer necessary (Def. Ex. J). On 31 January 1969 charges for the three absences were preferred. The accused remained under the control of civil authorities until 2 December 1971 without being tried for any of the alleged civil offenses. The accused’s military charges for the three absences were again preferred on 21 December 1971 and referred to a special court-martial on 22 December 1971. The accused, however, again absented himself without authority prior to trial on 12 January 1972 and remained so absent until 8 October 1973. The accused was subsequently tried by a general court-martial beginning on 15 January 1974 for four periods of absence without leave.

ISSUES

The defense has raised three assignments of error in this case. We find no merit to the alleged error concerning the defense counsel’s argument as to an appropriate sentence. We will discuss the two remaining assigned errors:

Since three specifications of absence without leave were initially preferred against the accused on 31 January 1969, the Government’s lack of diligence in bringing the appellant to trial amounted to an unreasonable delay, thereby denying him his right to a speedy determination of the three specifications of absence without leave.

II

The military judge erred to the substantial prejudice of the accused in denying trial defense counsel’s challenge for cause of a court member. The facts concerning this denial of the challenge will be presented later in this opinion.

DECISION

The key question presented by the first issue is whether the Government should be charged with the delay for the prosecution of the three absence without leave charges during the over two-year period when the accused was in the custody of civilian authorities.

The three absences occurred prior to the applicable date1 of the Burton2 rule and are not governed by the mandatory 90-day pretrial period test for delay. We shall therefore use the pre-Burton test and determine if the Government displayed an oppressive or purposeful design to delay appellant’s trial.3

The convening authority released the accused to civilian authorities, before charges were preferred, based upon the exercise of his sound discretion under the authority of [632]*632applicable regulations.4 The U. S. Army Court of Military Review has held that the use of this discretion to release an accused to civilian authorities causes the Government to be accountable for the time the offender is under the control of civilian authorities.5 The United States Air Force Court of Military Review has reached an opposite result. In the case of United States v. Steverson,6 the Air Force Court of Military Review ruled that the Government was not accountable for the delay during the period of state confinement. In the Steverson case the accused airman was apprehended on military charges by civil authorities and returned to military control. He was subsequently released to state officials for prosecution of state charges and the military charges were held in abeyance. The military offenses, although known to the Government at the time of release, were not preferred until the accused was again returned to military control. The preferral of the charges after return to military control is a distinguishing factor from the case, sub judice, however, this Court does not consider that this fact should make a difference in the ultimate resolution of the issue.

The appellate defense counsel places great stress upon United States v. Keaton,7 and argues that its holding is dispositive of this issue. We do not agree. Keaton concerned an accused’s apprehension by Government agents and his confinement by state officers on behalf of the Federal Government. In our case the state authorities requested and obtained custody of the accused for state charges on behalf of the state alone. At the time of delivery of the accused to the state authorities the Government ceased to have any control of the time and method of disposition of the accused’s alleged state criminal offenses. The accused during his pretrial confinement for the state charges did request military counsel to aid him in defending the state charges and requested information as to his military status. The record is not completely clear concerning the responses the accused received to these requests for information. He was informed that the absence without leave charges were preferred, but even assuming a partial failure to keep the accused informed in a timely manner of administrative procedures, this fact is not sufficient to charge the Government with a purposeful design. In any event, the military was under no duty to furnish the accused a military counsel to aid him in defense of his state criminal charges. The accused was provided with a military counsel upon his return to military control.

This Court holds that neither the U. S. Army Court of Military Review nor the United States Air Force Court of Military Review are correct in their respective determinations of the law in this area. A holding that the delay must always be chargeable to the Government ignores the compelling consideration of aiding a state jurisdiction for a timely disposition of criminal offenses without prejudicing the need for maintenance of order in the military. Conversely, a holding that the delay will never be charged to the Government ignores the possibility that the accused’s due process rights may be irreparably breached [633]*633due to the discretionary release of the accused by the convening authority to civilian authorities without first disposing of the accused’s military offenses. This possibility of an irreparable breach appears to be most crucial when the accused has an affirmative defense which requires the testimony of defense witnesses. Under these circumstances the accused’s transfer to civil authorities without trial of his military charges could result in his inability to later present an effective affirmative defense to the military charges. These considerations must be balanced, however, against the fact that the accused’s alleged civil misconduct can not be used by the author as a shield to prevent proper disposition of military charges. If the Government were always chargeable with the delay, an accused pending trial for military offenses may effectively terminate the military proceedings by his voluntary misconduct of a particularly heinous nature in the civilian community.

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Related

United States v. Tibbs
15 C.M.A. 350 (United States Court of Military Appeals, 1965)
United States v. Keaton
18 C.M.A. 500 (United States Court of Military Appeals, 1969)
United States v. Burton
21 C.M.A. 112 (United States Court of Military Appeals, 1971)
United States v. Rodgers
23 C.M.A. 389 (United States Court of Military Appeals, 1975)
United States v. Karnes
23 C.M.A. 537 (United States Court of Military Appeals, 1975)

Cite This Page — Counsel Stack

Bluebook (online)
1 M.J. 630, 1975 CMR LEXIS 715, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-sewell-usarmymilrev-1975.