United States v. Specialist KEVIN A. HUGGINS

CourtArmy Court of Criminal Appeals
DecidedMarch 20, 2015
DocketARMY 20121043
StatusUnpublished

This text of United States v. Specialist KEVIN A. HUGGINS (United States v. Specialist KEVIN A. HUGGINS) 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 KEVIN A. HUGGINS, (acca 2015).

Opinion

UNITED STATES ARMY COURT OF CRIMINAL APPEALS Before TOZZI, CAMPANELLA AND CELTNIEKS Appellate Military Judges

UNITED STATES, Appellee v. Specialist KEVIN A. HUGGINS United States Army, Appellant

ARMY 20121043

Headquarters, United States Army Africa Reynold P. Masterton, Military Judge Colonel Mark Tellitocci, Staff Judge Advocate

For Appellant: Colonel Kevin Boyle, JA; Lieutenant Colonel Peter Kageleiry, Jr, JA, Major Vincent T. Schuler, JA; Captain Brian J. Sullivan, JA (on brief)

For Appellee: Colonel John P. Carrell, JA; Lieutenant Colonel James L. Varley, JA; Major Robert A. Rodrigues, JA; Captain Benjamin W. Hogan, JA (on brief)

20 March 2015 ----------------------------------- MEMORANDUM OPINION -----------------------------------

This opinion is issued as an unpublished opinion and, as such, does not serve as precedent.

CAMPANELLA, Judge:

A panel of officer and enlisted members , sitting as a general court-martial convicted appellant, contrary to his pleas, of one specification aggravated assault with intent to commit infliction of grievous bodily harm and one specification of aggravated assault with a means likely to produce death or grievous bodily harm, in violation of Article 128, Uniform Code of Military Justice, 10 U.S.C. § 928 (2006) [hereinafter UCMJ]. The panel sentenced appellant to a bad-conduct discharge, confinement for sixty days, forfeiture of all pay and allowances, and reduction to the grade of E-1. The convening authority approved the sentence as adjudged and credited appellant with 20 days of confinement credit against the sentence to confinement. HUGGINS–ARMY 20121043

We now review appellant’s case under Article 66, UCMJ. Appellant raises three assignments of error, one of which warrants discussion and relief. Specifically, appellant argues the military judge erred by not merging the two aggravated assault specifications for findings as multiplicious. We agree.

BACKGROUND

Appellant was charged and found guilty of two specifications of aggravated assault in violation of Article 128, both arising from the same conduct. The government charged appellant using alternative theories as follows:

CHARGE II: VIOLATION OF THE UCMJ, ARTICLE 128

SPECIFICATION 1: In that [appellant], U.S. Army, did at or near Vincenza, Italy, on or about 1 May 2012, commit an assault upon [SPC JDB], by striking him in the head, face, and nose with a closed fist and did thereby intentionally inflict grievous bodily harm upon him, to wit: a fractured skull, right eye socket and nose.

SPECIFICATION 2: In that [appellant], U.S . Army, did at or near Vincenza, Italy, on or about 1 May 2012, commit an assault upon [SPC JDB], by striking him in the head, face, and nose with means and force likely to produce death or grievous bodily harm, to wit: a closed fist.

Prior to trial, defense counsel motioned the military judge to consolidate the aggravated assault specifications as multiplicious. Defense argued in the alternative that together the two specifications constituted an unreasonable multiplication of charges. During trial, the government stated the specifications were not multiplicious but rather were charged in the alternative. The military judge ruled that Specification 2 was not a lesser included offense of Specification 1 and denied the defense motion. The panel convicted appellant of both specifications.

After findings, the military judge again refused to dismiss one of the specifications reasoning that the two specifications had different elements and were not multiplicious. He did, however, merge them for sentencing. Appellant now argues he should only be convicted of a single specification of aggravated assault. We agree and accept the government’s concession in this regard.

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LAW AND DISCUSSION

Multipilcity

Whether an offense is a lesser-included offense is a question of law we review de novo. United States v. Arriaga, 70 M.J. 51, 54 (C.A.A.F. 2011) (quoting United States v. Miller, 67 M.J. 385, 387 (C.A.A.F. 2009) (citations omitted)). “The prohibition against multiplicity is grounded in com pliance with the ‘constitutional and statutory restrictions against Double Jeopardy.’” United States v. Gladue, 67 M.J. 311, 313 (C.A.A.F. 2009) (quoting United States v. Quiroz, 55 M.J. 334, 337 (C.A.A.F. 2001)). Accordingly, an accused may not be convicted and punished for two offenses where one is necessarily included in the other, absent congressional intent to permit separate punishments. See United States v. Teters, 37 M.J. 370, 376 (C.M.A. 1993).

We apply the elements test to determine whether one offense is a lesser included offense of another. United States v. Jones, 68 M.J. 465, 468-470 (C.A.A.F. 2010). “Under the elements test, one compares the elements of each offense. If all of the elements of offense X are also elements of offense Y, then X is an LIO of Y. Offense Y is called the greater offense because it contains all of the elements of offense X along with one or more additional elements.” Id. at 470. The elements test “permits lesser offense instructions only in those cases where the indictment contains the elements of both offenses,” and as a result “gives notice to the defendant that he may be convicted on either charge.” Schmuck v. United States, 489 U.S. 705, 718, (1989). “[A]pplying normal rules of statutory interpretation and construction, this Court will determine whether the elements of the LIO would necessarily be proven by proving the elements of the greater offense.” United States v. Wilkins, 71 M.J. 410, 412 (C.A.A.F. 2012). As normal principles of statutory construction may be employed in this determination, “[t]he elements test does not require that the two offenses at issue employ identical statutory language.” United States v. Alston, 69 M.J. 214, 216 (C.A.A.F. 2010). The ultimate rationale for the elements test is that “[t]he due process principle of fair notice mandates that 'an accused has a right to know what offense and under what legal theory’ he will be convicted.” Jones, 68 M.J. at 468 (quoting United States v. Medina, 66 M.J. 21, 26-27 (C.A.A.F. 2008)).

The elements of the aggravated assault with intent to commit infliction of grievous bodily harm are as follows:

(1) That the accused assaulted a certain person;

(2) That grievous bodily harm was thereb y inflicted upon such person;

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(3) That the grievous bodily harm was done with unlawful force or violence;

(4) That the accused, at the time, had the specific intent to inflict grievous bodily harm.

Manual for Courts-Martial, United States (2008 ed.) [hereinafter MCM], Part IV, ¶ 54.b.(4)(b); see also UCMJ art. 128(b)(2).

The offense of assault with a dangerous weapon or other means or force likely to produce death or grievous bodily harm contains the following elements:

(1) That the accused attempted to do, offered to do, or did bodily harm to a certain person;

(2) That the accused did so with a certain weapon, means, or force;

(3) That the attempt, offer, or bodily harm was done with unlawful force or violence;

(4) That the weapon, means, or force was used in a manner likely to produce death or grievous bodily harm .

MCM, Part IV, ¶ 54.b.(4)(a); see also UCMJ art. 128(b)(1).

While the language of the elements of each offense is not identical, a careful reading of the elements reveals the language of Art 128(b)(1) is a subset of Article 128(b)(2).

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Related

Schmuck v. United States
489 U.S. 705 (Supreme Court, 1989)
United States v. Arriaga
70 M.J. 51 (Court of Appeals for the Armed Forces, 2011)
United States v. Alston
69 M.J. 214 (Court of Appeals for the Armed Forces, 2010)
United States v. Jones
68 M.J. 465 (Court of Appeals for the Armed Forces, 2010)
United States v. Miller
67 M.J. 385 (Court of Appeals for the Armed Forces, 2009)
United States v. Gladue
67 M.J. 311 (Court of Appeals for the Armed Forces, 2009)
United States v. Medina
66 M.J. 21 (Court of Appeals for the Armed Forces, 2008)
United States v. Wilkins
71 M.J. 410 (Court of Appeals for the Armed Forces, 2012)
United States v. Winckelmann
73 M.J. 11 (Court of Appeals for the Armed Forces, 2013)
United States v. Quiroz
55 M.J. 334 (Court of Appeals for the Armed Forces, 2001)
United States v. Teters
37 M.J. 370 (United States Court of Military Appeals, 1993)

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