United States v. Specialist JAROD A. KUYKENDALL

CourtArmy Court of Criminal Appeals
DecidedDecember 16, 2025
Docket20230238
StatusUnpublished

This text of United States v. Specialist JAROD A. KUYKENDALL (United States v. Specialist JAROD A. KUYKENDALL) 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. Specialist JAROD A. KUYKENDALL, (acca 2025).

Opinion

UNITED STATES ARMY COURT OF CRIMINAL APPEALS Before FLOR, POND, and STEELE Appellate Military Judges

UNITED STATES, Appellee v. Specialist JAROD A. KUYKENDALL United States Army, Appellant

ARMY 20230238

Headquarters, Joint Readiness Training Center and Fort Polk Scott Z. Hughes, Military Judge (Motions) Maureen A. Kohn, Military Judge (Arraignment, Motions, and Trial) Colonel Leslie A. Rowley, Staff Judge Advocate

For Appellant: Lieutenant Colonel Autumn R. Porter, JA; Lieutenant Colonel Robert D. Luyties, JA; Captain Amir R. Hamdoun, JA (on brief).

For Appellee: Colonel Richard E. Gorini, JA; Captain Anthony J. Scarpati, JA (on brief).

16 December 2025

MEMORANDUM OPINION

This opinion is issued as an unpublished opinion and, as such, does not serve as precedent.

FLOR, Chief Judge:

Appellant was convicted by an enlisted panel, sitting as a general court­ martial, contrary to his pleas, of two specifications of sexual assault without consent, in violation of Article 120, Uniform Code of Military Justice, 10 U.S.C. § 920 [UCMJ]. 1 He was acquitted of one specification of sexual assault while incapable of consenting, in violation of Article 120, and one specification of assault consummated by a battery, in violation of Article 128.

Appellant raises four assignments of error: 1) whether the military judge erred by denying the defense motion for a continuance; 2) whether appellant's conviction

1 For purposes of clarity and efficiency, subsequent reference to the UCMJ will exclude citation to that work. KUYKENDALL -ARMY 20230238

for sexual assault without consent under Specification 1, Charge I is sufficient in light of United States v. Mendoza; 3) even if sufficient under Mendoza, whether appellant's conviction for sexual assault without consent under Specification 1, Charge I is factually sufficient because evidence of [the victim's] intoxication fails to meet the burden of proof required to show lack of consent and there was evidence of both consent and reasonable mistake of fact as to consent; and, 4) whether defense counsel were ineffective for failing to contact and present evidence from essential witnesses in sentencing.2 Though we discuss each assignment in turn, we affirm the findings, but remand this case or additional factfinding on the issue of ineffective assistance of counsel.

BACKGROUND Appellant and the victim were detailed as medics to support Cadet Summer Training (CST) at Fort Knox, Kentucky in May 2022. Both were assigned to Fort Polk, Louisiana but were from different units and had not met prior to CST. During CST, they interacted on an almost daily basis. Appellant was the senior medic for the company that they were both assigned to for CST.

They formed a relationship in June 2022 and engaged in consensual sexual intercourse on two occasions. Appellant was married to someone else at the time. Their relationship ended and as a result they were moved to different teams to avoid working together. Part of the reason for the relationship ending was that the victim had consensual sexual intercourse with someone else during this timeframe.

Appellant continued to pursue the victim romantically after this through text message and in-person while he was intoxicated during the 4th of July weekend. The following weekend, the medics had the weekend off. Four other medics planned a trip to Louisville where they rented an Airbnb. At some point during the trip, one of the medics discovered that she had left her wallet on Fort Knox. The medic who forgot her wallet texted the victim and asked her to bring the wallet. Because the victim had access to a Transportation Motor Pool (TMP) van as a part of her duties, she agreed and brought the wallet to Louisville.

Later, one of the other medics who knew appellant received a text from him stating that he wanted to join the group. The victim agreed to drive appellant from Fort Knox to hang out with this group of medics. After dropping appellant off with the group at the Airbnb, the victim had planned to return to Fort Knox. However, her cell phone died, and she did not have a charger with her, meaning that she did not have a way to guide herself back to Fort Knox. Consequently, the victim

2 We have given full and fair consideration to the matters personally raised by appellant pursuant to United States v. Grostefon, 12 M.J. 431 (C.M.A. 1982), and determine they merit neither discussion nor relief.

2 KUYKENDALL - ARMY 20230238

changed her plans and spent the night on a couch at the Airbnb. The following morning, the group asked her to stay the rest of the weekend since she had access to the TMP and could drive them around, to which she agreed.

The group spent the day drinking and hanging out. The victim drank two alcoholic seltzer drinks (5% alcohol by volume) and a margarita popsicle about ten inches in length (10% alcohol by volume). She felt drunk and, thinking she would vomit, went into the bathroom and hung over the toilet. After a while, one of the medics set her up in the bedroom with a trash can between her legs in case she got sick. The victim did not remember much after this point, but remembered seeing appellant sitting next to her on the bed. She did not remember what was said after he entered the room. Shortly thereafter, he flipped her over on her stomach, and he penetrated her vagina with his penis. This act constituted the sexual assault without consent in Specification I of Charge I, which appellant challenges before this court. The victim described herself as being in and out of consciousness, still severely intoxicated, and able to only recall snapshots. But she remembered appellant having sex with her by penetrating her vagina with his penis while she lay flat on her stomach. She also testified she did not consent.

The victim then went to sleep and woke up alone. A short while later, the victim ate dinner with the rest of the group. After dinner, the victim went to bed and appellant slept in the bed with her. The following morning, appellant tried to kiss the victim and made other attempts to engage her physically. In response to these advances, she kept pushing him away. Separately, she told him that she did not want to have sex with him. Appellant told her, "I'm not going to rape you." He then pushed her onto her back, removed her pants and underwear and had sex with her again. At trial, the victim described appellant's demeanor as "cold" and "stone faced" during this assault. This act constituted the sexual assault without consent in Specification 3 of Charge I, which appellant does not challenge before this court.

The victim helped the group clean up the Airbnb and the whole group went to breakfast. After breakfast, they went to a nearby nature reserve. One of the medics wanted to leave, so the victim drove him back to Fort Knox. On her way back to the reserve, she brought everyone Taco Bell. The victim was the only one not drinking that day, and they all needed a ride back to Fort Knox.

Appellant pulled the victim aside at one point for a private conversation. He told her that he wanted to be together and that he would leave his wife for her. The victim responded by telling him that she had been done with him for a while and that she did not want to have sex that morning. Appellant then lay down in the road and cried. Later, the victim agreed to speak with him at a picnic table at the reserve. Appellant again told her that he loved her, but then he threw up. Appellant became agitated and threw things off the table and continued to cry.

3 KUYKENDALL - ARMY 20230238

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

Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
United States v. Oliver
70 M.J. 64 (Court of Appeals for the Armed Forces, 2011)
United States v. Gooch
69 M.J. 353 (Court of Appeals for the Armed Forces, 2011)
United States v. Weaver
23 C.M.A. 445 (United States Court of Military Appeals, 1975)
United States v. Grostefon
12 M.J. 431 (United States Court of Military Appeals, 1982)
United States v. Robertson
39 M.J. 211 (United States Court of Military Appeals, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Specialist JAROD A. KUYKENDALL, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-specialist-jarod-a-kuykendall-acca-2025.