United States v. Simpson

2 M.J. 1125, 1976 CMR LEXIS 895
CourtU S Coast Guard Court of Military Review
DecidedMarch 1, 1976
DocketCGCM 9942
StatusPublished
Cited by1 cases

This text of 2 M.J. 1125 (United States v. Simpson) is published on Counsel Stack Legal Research, covering U S Coast Guard 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. Simpson, 2 M.J. 1125, 1976 CMR LEXIS 895 (cgcomilrev 1976).

Opinions

OPINION OF THE COURT

ROSENWASSER, Chief Judge:

There has been delivered to this Court 17 plastic boxes containing videocassettes and an assortment of papers for the Court’s appellate review under Article 66(b) UCMJ, 10 U.S.C. § 866(b). The material referred to us purports to be the record of trial in the general court-martial case of Seaman Recruit Mark J. Simpson, who contested the charges against him, was convicted on three counts, and was sentenced to a dishonorable discharge, forfeitures and confinement at hard labor for two years.

In due course an appellate defense brief containing nine assignments of error was submitted. We take note only of the first, which was assigned as follows:

I. THE JUDGE ERRED IN DENYING THE DEFENSE MOTION FOR A WRITTEN TRANSCRIPT OF THE COURT-MARTIAL PROCEEDINGS
A. THIS VIDEOTAPE TRANSCRIPT IS NOT IN FACT A VERBATIM TRANSCRIPT AS REQUIRED BY THE MANUAL FOR COURTS-MARTIAL
B. A VIDEOTAPE TRANSCRIPT FAILS AS A MATTER OF LAW TO SATISFY THE REQUIREMENT OF THE MANUAL FOR COURTS-MARTIAL FOR A VERBATIM TRANSCRIPT
C. THE COAST GUARD HAS NOT ADOPTED SUFFICIENT STANDARDS FOR THE USE OF VIDEOTAPE TRANSCRIPTS
D. THE USE OF A VIDEOTAPE TRANSCRIPT DEPRIVES THE DEFENDANT OF SUBSTANTIAL RIGHTS
1. RIGHT TO A COPY OF THE RECORD OF TRIAL
2. RIGHT TO EFFECTIVE ASSISTANCE OF APPELLATE COUNSEL
3. RIGHT TO A FAIR TRIAL
E. USE OF A VIDEOTAPE TRANSCRIPT DENIES THE DEFENDANT A PROPER APPELLATE REVIEW.

We directed that preliminary argument be heard, limited to these questions:

1) Whether a videotape transcript fails as a matter of law to satisfy the requirements of the Uniform Code of Military Justice and the Manual for Courts-Martial for a verbatim transcript; and
2) Whether the defendant has been deprived of due process or a fair trial as a result of the television videotaping of the trial proceedings.

A brief limited to the issues framed by the Court was submitted by government counsel, and we heard argument on 10 February 1976.

For the reasons stated below we find that a lawful “record” within the meaning of Article 66(c) is not before the Court, and that the videotapes without a transcript in writing do not satisfy the current requirements of law rements of law for producing a record of trial. We find further that Commandant Notice 5810 of 20 February 1975 which purported to authorize “the use of videotape as the transcript in general and special courts-martial” in the Coast [1127]*1127Guard is itself unauthorized and has no legal efficacy.

We deal here with a statutory system making it mandatory for this Court to review Simpson’s trial. Pertinent to the instant case, Congress directed that the trial counsel, under the direction of the court, “prepare the record of the proceedings” (Art. 38, 10 U.S.C. § 838); directed that “the record” be forwarded to the convening authority for initial action (Art. 60, 10 U.S.C. § 860); directed review by a legal officer prior to such action (Art. 61, 10 U.S.C. § 861); directed that “the entire record” be sent to the Judge Advocate General (Art. 65(a), 10 U.S.C. § 865(a)); directed the Judge Advocate General to refer “the record” to the Court of Military Review (Art. 66(b)); and directed the Court of Military Review to determine the findings and sentence which should be approved “on the basis of the entire record” (Art. 66(c)). Further, Congress empowered the Court of Military Review “in considering the record” to weigh the evidence and judge the credibility of witnesses “recognizing that the trial court saw and heard the witnesses.” (Congress did not envision the Courts of Military Review also seeing and hearing the witnesses.) Congress, in enacting the UCMJ did not deem it necessary to prescribe the form, contents or other details as to records of trial. But Congress did enact into positive law the requirement for a record. As to general courts-martial, Article 54, 10 U.S.C. § 854 states:

(a) Each general court-martial shall keep a separate record of the proceedings in each case brought before it.

And, the official commentary on Article 54(a) said:

It is intended that records of a general courts-martial shall contain a verbatim transcript of the proceedings.1

Since Congress did not legislate on what would constitute “the record” mentioned in the cited Articles of the Code, one must look elsewhere. The power to make rules concerning records of trial was given to the President. That power derives from Article 36, 10 U.S.C. § 836, whereby Congress delegated to the President the authority to make procedural rules, with the limitation that they not be contrary to or inconsistent with the Code. By Article 140, 10 U.S.C. § 940, Congress permitted the President to redelegate his rule-making authority. In United States v. Smith, 13 U.S.C.M.A. 105, 32 C.M.R. 105 (1962) the Court of Military Appeals found Article 36 to be a valid delegation of power to the President, stating that

the rule is well established that Congress may delegate to the President . the power to make regulations to fill up details and implement statutory provisions, or to determine the details of the legislative scheme. And, further, when regulations are so adopted, they “have the force of law.” (p. 118)

The Manual for Courts-Martial represents an exercise by the President of his legal authority under Article 36. We see from the Manual that the President extensively exercised his power to make rules with regard to records of trial, while redelegating very little of this authority. He devoted a chapter in the Manual to “Records of Trial” — Chapter XVI, with paragraph 82 and nine subparagraphs covering records in general courts-martial, and paragraph 83 covering inferior courts-martial. He also made rules concerning records of trial in other parts of the Manual. See, for example, Appendix 9, furnishing a guide for “when a verbatim record is prepared”; paragraph 49, directing what the reporter must do and may do; paragraph 15b, demanding “a complete and verbatim record” for BCD special courts-martial; and paragraph 79 e prescribing procedures applicable to summary court records, but with permission to the Secretary of a Department to “otherwise prescribe by regulations.”

Paragraph 82b of the chapter on Records of Trial, in both the 1951 and the 1969 [1128]

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Related

United States v. Barton
6 M.J. 16 (United States Court of Military Appeals, 1978)

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Bluebook (online)
2 M.J. 1125, 1976 CMR LEXIS 895, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-simpson-cgcomilrev-1976.