United States v. Specialist STEVEN A. HOLMES

CourtArmy Court of Criminal Appeals
DecidedJune 10, 2025
Docket20240106
StatusUnpublished

This text of United States v. Specialist STEVEN A. HOLMES (United States v. Specialist STEVEN A. HOLMES) 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 STEVEN A. HOLMES, (acca 2025).

Opinion

UNITED STATES ARMY COURT OF CRIMINAL APPEALS

Before FLEMING, COOPER, and SCHLACK Appellate Military Judges

UNITED STATES, Appellee v. Specialist STEVEN A. HOLMES United States Army, Appellant

ARMY 20240106

Headquarters, 1st Infantry Division and Fort Riley Steven C. Henricks, Military Judge (arraignment) Scott A. Oravec, Military Judge (motion) Gregory R. Bockin, Military Judge (trial) Colonel Toby N. Curto, Staff Judge Advocate

For Appellant: Major Beau O. Watkins, JA (argued); Colonel Phillip M. Staten, JA; Lieutenant Colonel Autum R. Porter, JA; Major Beau O. Watkins, JA (on brief).

For Appellee: Captain Stewart A. Miller, JA (argued); Colonel Richard E. Gorini, JA; Major Justin L. Talley, JA; Captain Stewart A. Miller, JA (on brief).

10 June 2025

This opinion is issued as an unpublished opinion and, as such, does not serve as precedent.

COOPER, Judge:

Appellant raises two assignments of error, one of which merits discussion but no relief.! Appellant alleges the military judge failed to strike the victim’s testimony or declare a mistrial under Rule for Courts-Martial [R.C.M.] 914 after the government lost a recording of the victim’s statement to the Army Criminal Investigative Division (CID). While we analyze this claim below, we find no relief is warranted.

| We have reviewed appellant’s other assignment of error as well as the issue personally raised by appellant pursuant to United States v. Grostefon, 12 M.J. 431 (C.M.A. 1982) and find they warrant neither discussion nor relief. HOLMES — ARMY 20240106 BACKGROUND

An enlisted panel, sitting as a general court-martial, convicted appellant, contrary to his pleas, of one specification of domestic violence, one specification of unlawfully carrying a concealed weapon, and one specification of failure to obey a lawful order, in violation of Articles 128b, 114, and 92, Uniform Code of Military Justice, 10 U.S.C. §§ 928b, 914, and 892 [UCMIJ]. The military judge sentenced appellant to 45 days of confinement and 30 days of hard labor. The convening authority approved the findings and only so much of the sentence that extended to 45 days of confinement.

In October of 2021, appellant and BB net at Fort Riley, Kansas, and after dating for about a month, moved into appellant’s on post residence. On 10 April 2022, informed appellant she no longer wanted to be together and was moving out. testified appellant became angry when she told him the relationship was over. Appellant pushed her into a wall as she tried to leave. a testified she ran out of the house and saw appellant following her, carrying a pistol.

a initially reported the incident to the Military Police (MP). Based ona separate allegation of sexual assault, the MPs turned the case over to CID. On 15 September 2022, 7 was interviewed for approximately two hours by CID concerning her allegations of domestic violence and sexual assault, during which an agent took contemporaneous notes. Additionally, the interview was recorded and stored on a standalone computer with CaseCracker software. The computer allowed for storage of interviews, and CID relied on this capability when conducting their investigations.

In the fall of 2022, the standalone computer crashed and over a hundred interviews were lost. The CID agents initiated a standard recovery process and recovered the majority of the interviews. However, some could not be recovered, including s interview. The CID agents contacted CaseCracker Onyx, the company responsible for the software, for additional recovery assistance to no avail.

Prior to trial, appellant’s defense counsel requested a copy of Ms interview. The government informed them the interview was lost in the computer crash and could not be recovered. Defense did however receive the CID agent’s contemporaneous notes. Defense counsel filed a pretrial motion to abate the proceedings until the government could produce the recording. The military judge denied appellant’s motion to abate, ruling that while the government did violate R.C.M. 914, the good faith exception applied as the loss of the recording was not the result of gross negligence or bad faith on the part of CID. Therefore, the military judge determined abatement was not an appropriate remedy for the violation and instead granted defense “substantial leeway” in its cross-examination of mm HOLMES — ARMY 20240106 LAW AND DISCUSSION

We review a military judge’s decision on whether to strike testimony under R.C.M. 914 for an abuse of discretion. United States v. Clark, 79 M.J. 449, 453 (C.A.A.F. 2020); United States v. Muwwakkil, 74 M.J. 187, 191 (C.A.A.F. 2015). An abuse of discretion occurs when a military judge’s findings of fact are clearly erroneous or his conclusions of law are incorrect. Clark, 79 M.J. at 453; United States v. Olson, 74 M.J. 132, 134 (C.A.A.F. 2015).

Rule for Courts-Martial 914, at the time of this case, stated: “After a witness other than the accused has testified on direct examination, the military judge, on motion of a party who did not call the witness, shall order the party who called the witness to produce, for examination and use by the moving party, any statement of the witness that relates to the subject matter concerning which the witness has testified.” R.C.M. 914(a). The rule provides the military judge with two remedies for the government’s failure to deliver the statement in question: 1) strike the testimony of the witness, or 2) “declare a mistrial if required in the interest of justice.” R.C.M. 914(e).

Existing case precedent by our superior court has long recognized “a judicially created good faith loss doctrine.”? United States v. Sigrah, 82 M.J. 463, 471 (C.A.A.F. 2022) (quoting Muwwakkil, 74 M.J. at 193). “The good faith loss doctrine ‘excuses the Government’s failure to produce statements if the loss or destruction of evidence was in good faith.’” Muwwakkil, 74 M.J. at 193. “[A]lthough the text of R.C.M. 914(e) requires a military judge to strike a witness’s testimony or declare a mistrial if the government does not produce a witness’s statements, our precedent holds that a military judge cannot strike the testimony or declare a mistrial if the government acted in good faith.” Sigrah, 82 M.J. at 471(Maggs, concurring) (see also United States v. Marsh, 21 M.J. 445, 452 (C.M.A. 1986)).

As the military judge correctly pointed out in his ruling, there is no doubt that R.C.M. 914 was triggered in this case. If BB estified at trial, the government would be unable to produce the recording, thereby violating the plain language of the rule.

* The enumerated exceptions in the current version of R.C.M. 914, pursuant to 2023 Amendments to the MCM, did not take effect until 28 July 2023, almost two weeks after appellant’s arraignment. Executive Order 14103, dated 28 July 2023, states: “Nothing in Annex 1 shall be construed to invalidate any ... trial in which arraignment occurred...begun prior to the date of this order, and any ... trial in which arraignment occurred...may proceed in the same manner and with the same effect as if the Annex 1 amendments had not been prescribed.” Exec. Order No. 14103, 88 C.F.R. 50535 (2023). However, insofar as the amendment addresses an exception where the loss is not attributable to bad faith or gross negligence, it is merely a codification of existing case precedent. HOLMES — ARMY 20240106

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Related

Conway v. O'Brien
312 U.S. 492 (Supreme Court, 1941)
United States v. Olson
74 M.J. 132 (Court of Appeals for the Armed Forces, 2015)
United States v. Muwwakkil
74 M.J. 187 (Court of Appeals for the Armed Forces, 2015)
United States v. Grostefon
12 M.J. 431 (United States Court of Military Appeals, 1982)
United States v. Marsh
21 M.J. 445 (United States Court of Military Appeals, 1986)

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