United States v. Sonego

61 M.J. 1, 2005 CAAF LEXIS 363, 2005 WL 756768
CourtCourt of Appeals for the Armed Forces
DecidedApril 1, 2005
Docket04-0480/AF
StatusPublished
Cited by10 cases

This text of 61 M.J. 1 (United States v. Sonego) 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. Sonego, 61 M.J. 1, 2005 CAAF LEXIS 363, 2005 WL 756768 (Ark. 2005).

Opinions

Judge ERDMANN

delivered the opinion of the Court.

Airman Michael Sonego entered a plea of guilty to wrongful use of ecstasy in violation of Article 112a, Uniform Code of Military Justice (UCMJ), 10 U.S.C. § 912a (2000). He was sentenced by members to a bad-[2]*2conduct discharge, restriction to the limits of Lackland Air Force Base for two months, forfeiture of $500 pay per month for twelve months, and a reduction in grade to E-l. The convening authority approved only the bad-conduct discharge and partial forfeitures. The findings and the approved sentence were affirmed by the United States Air Force Court of Criminal Appeals in an unpublished opinion. United States v. Sonego, 59 M.J. 477 (A.F.Ct.Crim.App.2004).

After Sonego’s trial, his defense counsel discovered that one of the panel members may have failed to answer a question honestly during voir dire. Voir dire is critical to the fairness of a court-martial. United States v. Mack, 41 M.J. 51, 54 (C.M.A.1994). A defendant’s right to a fair trial is undermined if panel members fail to answer material questions honestly during voir dire. Id. We granted review to determine whether Sonego was entitled to any post-trial relief.1

BACKGROUND

Sonego was accused of taking two ecstasy pills on two consecutive days in January 2002. When questioned by investigators, he immediately confessed to his misconduct. At trial Sonego pleaded guilty and was sentenced by a panel of three officer members.

During voir dire, the military judge asked the standard voir dire questions found in the Military Judges’ Benchbook. Legal Services, Dep’t of the Army, Pamphlet 27-9, Military Judges’ Benchbook ch. 2, § V, para. 2-5-1 (2001). Among the questions the military judge asked was:

It is a ground for challenge if you have an inelastic predisposition toward the imposition of a particular punishment based solely on the nature of the crime for which the accused is to be sentenced. Does any member, having read the charge and specification!;,] believe that you would be compelled to vote for any particular punishment solely because of the nature of the charge?

See id. Captain Bell, who was a potential member, answered “no” and was subsequently seated on the panel. He was not called for individual voir dire.

Bell was an active participant in the sentencing proceedings. When the first witness was testifying, Bell was the only panel member to respond to a question from the military judge about the members’ ability to hear the testimony. During the defense’s ease, after Sonego’s mother had testified about Sonego’s background and character, Bell asked the military judge whether the members would have access to documents that would show whether Sonego had used drugs before he enlisted in the Air Force.

During the deliberations the members sent a note to the military judge asking if there were any discharge options available other than a bad-conduct discharge. The military judge called the members in and explained that the only discharge option available to the court was a bad-conduct discharge. When the military judge asked if there were any further questions, Bell asked whether there would be mandatory confinement time associated with a punitive discharge. The military judge told the court that confinement was not required even if Sonego was sentenced to a bad-conduct discharge.

Nearly a month after the trial, Sonego’s trial defense counsel, Captain Page, was representing another airman in a drug case when Bell was again selected to sit on the panel. During voir dire in the second case, Bell expressed a predisposition that any ser-vicemember convicted of a drug offense should receive a bad-conduct discharge. Bell was subsequently challenged for cause and removed from the panel.

No transcript was made in the second case because it resulted in an acquittal, but Page later drafted a sworn declaration in which he recounted Bell’s different responses in the two cases. Page’s declaration did not include the specific wording of any questions asked [3]*3of the panel in general or of Bell in particular. On appeal to the Court of Criminal Appeals, Sonego requested a new sentence proceeding that was supported by Page’s declaration. That court denied the request on the ground that Sonego had not demonstrated that Bell failed to answer any question honestly.

Before this Court, Sonego argues that Bell failed to reveal his true beliefs during voir dire, and, that had he revealed his true feelings about drug use by members of the military, Bell could have been successfully challenged for cause. Sonego argues that his sentence — which included a bad-conduct discharge but no confinement — was so moderate as to indicate that he might have avoided a punitive discharge altogether if Bell had not been a member of the panel. Sonego further argues that he should be given a new sentence hearing, or, in the alternative, a trial-level evidentiary hearing to develop the facts further.

The Government’s response was that Sone-go is not entitled to a new sentence hearing or even an evidentiary hearing because he has not established that Bell failed to disclose information during voir dire. The Government argues that the accused must make a prima facie showing of nondisclosure before an evidentiary hearing can be ordered.

DISCUSSION

In McDonough Power Equipment, Inc. v. Greenwood, 464 U.S. 548, 556, 104 S.Ct. 845, 78 L.Ed.2d 663 (1984), the United States Supreme Court set out the test for determining when a party is entitled to a new trial due to an incorrect voir dire response: “[T]o obtain a new trial in such a situation, a party must first demonstrate that a juror failed to answer honestly a material question on voir dire, and then further show that a correct response would have provided a valid basis for a challenge for cause.” We adopted this test in Mack, and held that “where a party asserts juror nondisclosure during voir dire as a ground for a new trial, the normal procedure is to remand the issue to the trial court for resolution.” 41 M.J. at 55. In United States v. Humpherys, we reiterated, “[A]n evidentiary hearing is the appropriate forum in which to develop the full circumstances surrounding each of [the Mack/McDonough] inquiries.” 57 M.J. 83, 96 (C.A.A.F.2002). We did not order an evidentiary hearing in Humpherys, however, because the military judge had already conducted a post-trial session under Article 39(a), UCMJ, 10 U.S.C. § 839(a) (2000), after which he applied the McDonough test. 57 M.J. at 95.

Although an evidentiary hearing is the usual procedure for resolving claims of juror dishonesty, we have not had the occasion to address the measure of proof required to trigger an evidentiary hearing. The measure of proof required to trigger a McDonough evidentiary hearing is a question where the federal circuits have differed. Of the eight circuits that have addressed this issue, six have adopted a standard that requires something less than proof of juror dishonesty before a hearing is convened. See United States v. Carpa,

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Cite This Page — Counsel Stack

Bluebook (online)
61 M.J. 1, 2005 CAAF LEXIS 363, 2005 WL 756768, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-sonego-armfor-2005.