United States v. Specialist JESUS O. NAVARRO

CourtArmy Court of Criminal Appeals
DecidedMarch 30, 2026
Docket20250171
StatusUnpublished

This text of United States v. Specialist JESUS O. NAVARRO (United States v. Specialist JESUS O. NAVARRO) 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 JESUS O. NAVARRO, (acca 2026).

Opinion

UNITED STATES ARMY COURT OF CRIMINAL APPEALS Before MORRIS, JUETTEN, and MURDOUGH Appellate Military Judges

UNITED STATES, Appellee v. Specialist JESUS 0. NAVARRO United States Army, Appellant

ARMY 20250171

Headquarters, First Cavalry Division Javier E. Rivera-Rosario, Military Judge Lieutenant Colonel Shaun B. Lister, Special Trial Counsel

For Appellant: Major Peter M. Ellis, JA; Captain Emily R. Ittner, JA (on brief).

For Appellee: Captain Nicholas A. Schaffer, JA (on brief).

30 March 2026

SUMMARY DISPOSITION UPON RECONSIDERATION

This opinion is issued as an unpublished opinion and, as such, does not serve as precedent.

Per Curiam:

A military judge, sitting as a general court-martial, convicted appellant, pursuant to his pleas, of one specification of wrongfully possessing child pornography in violation of Article 134, Uniform Code of Military Justice, 10 U.S.C. § 934 [UCMJ]. Pursuant to the plea agreement requiring a fixed sentence, the military judge sentenced appellant to a bad-conduct discharge, with no other punishment.

Appellant submitted this case with no specific assignments of error, but personally submitted fourteen separate issues pursuant to United States v. Grostefon, 12 M.J. 431 (C.M.A. 1982). 1 One of these Grostefon matters alleges that appellant received ineffective assistance of counsel from his detailed trial defense counsel.

1 We have given full and fair consideration to these other matters and determine they merit neither discussion nor relief. N AVARRO - ARMY 20250171

Appellant alleged six specific instances of deficient conduct. In fulfillment of our duty to give full and fair consideration to matters personally submitted pursuant to Grostefon, we determined that two of his allegations were conclusively resolved based on the record alone. See United States v. Ginn, 47 M.J.236,244 (C.A.A.F. 1997). However,four of his allegations could not be adequately resolved by the record and were asserted with such specificity that we found the matter unresolvable on the record alone,therefore we ordered defense counsel to submit an affidavit.

After receiving his affidavit, we initially summarily affirmed the findings and sentence. In a footnote to our decision,we noted appellant had asserted his claim of ineffective assistance "without any supporting evidence." The same day we issued our decision,the court received from appellant a motion to attach a subsequent, unsworn affidavit. In his affidavit, appellant asserted he "believe[d]" his defense counsel had not viewed the video of his interview and that defense counsel had strongly recommended accepting the plea agreement,discouraged. him from pursuing other avenues,including requesting an administrative discharge instead of trial by court-martial, and failed to properly advise him on matters he could submit to the convening authority for consideration of clemency per Rule for Courts-Martial [R.C.M.]1106.

We granted the motion to attach. Based on the motion,we elected to sua sponte reconsider our prior decision; this election was later joined by appellant's own motion for reconsideration.2 Now having considered both affidavits alongside the trial record, we again determine defense counsel's performance was not ineffective, and we again affirm the findings and sentence.3

2 In his motion to reconsider,appellant notes he filed a motion to attach his unsworn affidavit on 19 March 2026. While appellant may have moved to attach his affidavit on 19 March,his filing was not accepted by the court until the next day,the day our decision was entered and approximately two weeks after we received the affidavit from trial defense counsel. Our grant of the motion to attach and reconsideration of this issue should not be read as endorsing the protracted and dilatory way appellant chose to submit matters for our consideration. 3 Here, we are not faced with conflicting affidavits. See Ginn, 47 M.J.at 244 ("a Court of Criminal Appeals [may not]decide disputed questions of fact pertaining to a post-trial claim,solely or in part on the basis of conflicting affidavits submitted by the parties."). For example, appellant assertion that defense counsel failed to investigate is inherently speculative. Id. at 248 ("if the affidavit ...consists instead of speculative or conclusory observations,the claim may be rejected on that basis."). Moreover, "the record as a whole," including "appellate filings " "compelling demonstrate[s]" the improbability of appellant receiving an administrative discharge given the offenses he faced, discussed infra. Id.

2 NAVARRO -ARMY 20250171

LAW AND ANALYSIS

We review claims of ineffective assistance of counsel de novo. United States v. Suarez, 86 M.J. 65, 73 (C.A.A.F. 2025) (citation omitted). "Under Strickland [v. Washington, 466 U.S. 688 (1984)], an appellant bears the burden of demonstrating that (a) defense counsel's performance was deficient, and (b) this deficient performance was prejudicial." Id. (quoting United States v. Furth, 81 M.J. 114, 117 (C.A.A.F. 2021)). In the context of a guilty plea, "the defendant must show that there is a reasonable probability that, but for counsel's errors, he would not have pleaded guilty and would have insisted on going to trial." United States v. Bradley, 71 M.J. 13, 16 (C.A.A.F. 2012) (quoting Hill v. Lockhart, 474 U.S. 52, 59 (1985)).

The primary thrust of appellant's ineffective assistance claims is his defense counsel pushed him toward a plea agreement, rather than an administrative discharge in lieu of court-martial (commonly referred to as a "Chapter 10").4 Defense counsel asserts he negotiated a favorable disposition with the trial counsel, one to which, based on email communications provided by defense counsel, the trial counsel was perhaps not even authorized to agree, but nonetheless the referral authority agreed to honor, provided the case moved quickly. Defense counsel also provided a screenshot of a text exchange with appellant where not only did he explain the difference between a Chapter 10 administrative discharge and a conviction, but also explained how a Chapter 10 was a unlikely outcome, to which appellant agreed that the plea agreement "Seems like it's the best option." Defense counsel negotiated a plea agreement whereby appellant would not spend a single day in confinement despite a conviction for possessing child pornography; his desire and advice to move quickly to avoid losing that agreement, without submitting a likely futile request for an alternate disposition, is well within the range of acceptable conduct.

Appellant, in his affidavit, repeats his assertion that he would have pursued an administrative discharge in lieu of trial had he known it was a possibility, and he asserts he would not have pled guilty but for counsel's errors. However, appellant affirmed under oath that it was his express desire to be discharged with a bad­ conduct discharge, even knowing administrative separation was possible, in order to get the benefit of his agreement. And finally, after affirming under oath that he was satisfied with defense counsel and the advice he had given him, and that appellant understood he had the absolute right to plead not guilty and place upon the government the burden of proving his guilt beyond a reasonable doubt, the military judge asked appellant to pause, consult with his defense counsel again, and once again affirm whether or not he still wanted to plead guilty. Appellant stated he did. In other words, at multiple stages, right up to the moment his plea was accepted,

4 See generally Army Reg.

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

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
United States v. Bradley
71 M.J. 13 (Court of Appeals for the Armed Forces, 2012)
United States v. Grostefon
12 M.J. 431 (United States Court of Military Appeals, 1982)

Cite This Page — Counsel Stack

Bluebook (online)
United States v. Specialist JESUS O. NAVARRO, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-specialist-jesus-o-navarro-acca-2026.