United States v. Staff Sergeant RICHARD T. RIDDLE

Army Court of Criminal Appeals·Decided August 27, 2026·No. 20230520·Unpublished

Opinion

UNITED STATES ARMY COURT OF CRIMINAL APPEALS Before

COOPER, WILLIAMS, and JUETTEN Appellate Military Judges

UNITED STATES, Appellee

v.

Staff Sergeant RICHARD T. RIDDLE United States Army, Appellant

ARMY 20230520

Headquarters, 8th Theater Sustainment Command Michael E. Korte and Robert E. Murdough, Military Judges Lieutenant Colonel Christofer T. Franca, Staff Judge Advocate

For Appellant: Captain Jessica A. Adler, JA (argued); Colonel Frank E. Kostik, Jr., JA; Lieutenant Colonel Kyle C. Sprague, JA; Jonathan F. Potter, Esquire; Captain Jessica A. Adler, JA (on brief and reply brief).

For Appellee: Captain Melissa D. Zigrang, JA (argued); Colonel Richard E. Gorini, JA; Major Vy T. Nguyen, JA; Major Stephen Harmel, JA; Captain Clare Murphy, JA (on brief).

27 August 2026

MEMORANDUM OPINION

This opinion is issued as an unpublished opinion and, as such, does not serve as precedent.

WILLIAMS, Judge:

The military judge afforded appellant multiple opportunities to object to the proposed findings instructions and solicited appellant's input on their content. Appellant neither objected nor proposed alternate language. Accordingly, appellant waived any error as to the instructions. Separately, appellant's anger does not permit him to utter vulgarities. Consequently, we affirm the findings and sentence of appellant's court-martial. 1

1 We have given full and fair consideration to the other matters alleged as error by appellant, both through counsel and personally pursuant to United States v. Grostefon, 12 M.J. 431 (C.M.A. 1982), and determine they warrant neither

(continued . . .)

RIDDLE - ARMY 20230520

A general court-martial composed of officer and enlisted members convicted appellant,contrary to his pleas,of one specification of kidnapping,one specification of assault with intent to commit sexual assault,and one specification of indecent language,in violation of Articles 125,128,and 134,Uniform Code of Military Justice,10 U.S.C.§§ 925,928,934 [UCMJ]. During an earlier session of the court­ martial,appellant was convicted,consistent with his pleas,of two specifications of absence without leave,four specifications of disrespect toward a superior commissioned officer,two specifications of willfully disobeying a superior officer, nine specifications of insubordinate conduct,and one specification of assault upon a person in the execution of law enforcement duties,in violation of Articles 86,89, 90,91,and 128,UCMJ. The military judge sentenced appellant to a dishonorable discharge and to be confined for 116 months and 25 days.

BACKGROUND

The victim fell asleep,on her stomach,in appellant's bed. At some point,the victim awoke and noticed the blanket she had been using no longer covered her legs or buttocks; it was pulled up to her waist. Appellant had positioned himself so his knees "secur[ed] [the] blanket down over [her] waist " and pinned the victim to the bed. While in this position,appellant anally penetrated the victim,causing her pain. Per the victim's testimony,she woke "up to [a] sudden realization that [appellant] was having sex with [her]." After she awoke,appellant held her down while having sex with her. The victim said, "Ouch," " Stop," and "You're hurting me," but appellant did not stop. Appellant ceased his assault after he ejaculated. Consequently, the government preferred and referred the Specification of Charge I that alleged appellant sexually assaulted a sleeping person.

The military judge discussed the findings instructions during an Article 39(a)

hearing. The military judge asked counsel if there were any lesser included offenses (LIOs) for the charged offenses. Trial counsel said "yes." Trial counsel noted assault with intent to commit sexual assault was appropriate for the charged sexual

(...continued) discussion nor relief. Further,appellant's assertions his counsel were ineffective byfailing to call particular witnesses,to investigate,and to object to the findings instructions are unavailing. To address his claims,we ordered affidavits from appellant's trial defense team. Mindful of our superior court's guidance in United States v. Ginn, 47 M.J.236 (C.A.A.F.1997),we are capable of resolving appellant's allegations without ordering any additional proceedings. Simply stated,defense counsel appropriately investigated appellant's case and had reasonable and strategic reasons behind their presentation of evidence. Accordingly, they were not ineffective. Regarding appellant's allegation they were ineffective for failing to object to instruction on a lesser included offense,we address that assertion in greater depth later in this opinion.

RIDDLE - AR MY 20230520

assault offense. Initially,defense counsel hesitated and stated, "I'm not sure I [agree], Your Honor." The military judge confirmed with trial counsel that assault with intent to commit sexual assault was presidentially prescribed as an LIO for sexual assault. The military judge then directed trial defense counsel to Appendix 12A of the Manual for Courts-Martial, United States (2019 ed.) [MCM]. After defense counsel reviewed the appendix,the military judge asked again, "Do you still disagree?" Defense counsel responded, "I understand, Your Honor." The military judge followed up and asked, "Do you object to the instruction?" Defense counsel answered, "I do not,Your Honor."

The military judge requested contributions from both parties on the content and form of the instructions throughout the Article 39(a) hearing. Specifically,he sought input about the language of the LIO instruction. The military judge observed the draft instruction had a parenthetical that required a description of the "manner of the assault and battery alleged," and asked trial counsel to describe their theory of liability for the LIO. Trial counsel stated,"sexual assault by holding ...[the victim] down and penetrating her anus with his penis." The military judge asked defense counsel, "do you concur in that parenthetical or do you have different language?" Defense counsel responded "Your Honor,I do not have different language.I can't even conceive of what other - I mean,I believe that that's for lack of a better word,the only thing that's been received." After discussing the mens rea required for the LIO,the military judge asked the parties if there was "[a]nything else on the lesser-included of assault with intent?" Defense counsel responded, "No, Your Honor." Prior to closing the Article 39(a) hearing,the military judge asked, "Are there any other instructions that either side would request?" Both trial counsel and trial defense counsel said, "no."

The military judge stated he would type the instructions and send them to the parties to review. He "strongly recommend[ed] both sides ...print [the instructions] and read [them] " because "[t]he act of passively scrolling on a screen " causes one to miss errors. The military judge provided the instructions and permitted counsel to review them overnight. Both trial counsel and defense counsel submitted corrections that the military judge incorporated into the findings instructions. The following morning,the military judge held a Rule for Courts­ Martial [R.C.M.] 802 conference with counsel,during which they "went page by page through the findings instructions," resulting in the incorporation of additional "minor syntactical changes." Defense counsel proposed a substantive change to the indecent language specification, and the military judge accommodated that request. Finally, on the record,the military judge confirmed with trial counsel and defense counsel that they had reviewed the findings instructions and that they reflected all changes discussed. He asked whether either side "ha[d] any objections other than

RIDDLE - ARMY 20230520

what we've already covered?"2 Defense counsel replied, "No, Your Honor." The panel found appellant guilty of the LIO.

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