United States v. Valles-Santana

2 M.J. 1049, 1976 CMR LEXIS 677
CourtU.S. Army Court of Military Review
DecidedNovember 18, 1976
DocketCM 433544
StatusPublished
Cited by6 cases

This text of 2 M.J. 1049 (United States v. Valles-Santana) is published on Counsel Stack Legal Research, covering U.S. Army Court of Military Review primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Valles-Santana, 2 M.J. 1049, 1976 CMR LEXIS 677 (usarmymilrev 1976).

Opinions

[1050]*1050DECISION ON FURTHER REVIEW

DeFORD, Judge:

The appellant, contrary to his pleas, was convicted by a military judge sitting as a general court-martial of possession and sale of lysergic acid diethylamide on three occasions in violation of Article 134, Uniform Code of Military Justice (10 U.S.C. § 934) and received the approved sentence set forth above.

In our initial review of this case, we affirmed the findings of guilty and the approved sentence set forth above. However, on 4 March 1976, the United States Court of Military Appeals vacated our decision and remanded the record of trial to this Court with directions to hold further proceedings in abeyance pending that Court’s decision in United States v. McCarthy, No. 30,560 then pending before that Court. United States v. McCarthy, 2 M.J. 26 (24 September 1976) has now been decided and we are at liberty to proceed with the determination of whether the original court-martial had jurisdiction over Charge I and its six specifications.

The operative facts with which we are concerned are as follows: The first region of the Criminal Investigation Command (CID) was conducting covert operations against military personnel who were selling prohibited drug substances in the vicinity of Fort Dix, New Jersey during October and November 1974. Three CID agents disguised as civilians, engaged a civilian by the name of James Murray, who was a known drug trafficker, to make the initial contacts. For each sale consummated, the contact received ten percent of the purchase price paid for the illicit drugs. The contact was being used as an informer although the individual concerned was not aware he was associated with CID agents. This covert operation and others were coordinated with local law enforcement agencies.

On 20 November 1974, the local contact Murray made an arrangement with a Private First Class Carr to contact the appellant to set up a sale. Carr advised Murray to have his principals meet at a barracks in the 5th Brigade Area on the reservation at Fort Dix, New Jersey at 1630 hours. Private Carr, James Murray, and Agents Chiofolo and Kimberlin arrived at the barracks area. Shortly thereafter, the accused in uniform arrived. Chiofolo, Carr, and the accused entered a barracks room at which time the accused agreed to sell to Chiofolo 200 “hits” of LSD for the sum of $500.00. The accused instructed Chiofolo to meet him in the parking lot of a night club in nearby Springfield Township, New Jersey later that evening. At the appropriate time, the parties met at the appointed place. Agents Chiofolo and Kimberlin entered the appellant’s van. The appellant, Carr and an unidentified person were present in uniform in the van and the appellant gave Chiofolo two strips of paper each containing 100 hits of LSD. Upon examination, Agent Chiofolo directed Agent Kimberlin to pay the agreed $500.00 purchase price to the appellant.

Subsequently, on 23 November 1974, the agents proceeded to the home of the contact Murray in Mount Holly, New Jersey, presumably based upon information that an additional purchase could be made. Upon arrival, they found the appellant sitting in his vehicle in front of Murray’s house. The parties entered the house and the appellant offered to sell an additional 200 hits of LSD for $450.00. The agents agreed to the purchase and the appellant returned to his vehicle and removed a record album from which he removed two pieces of paper containing the illicit LSD and the sale was consummated.

On 26 November 1974, an additional purchase was negotiated through the contact Murray. The parties met again at the night club parking lot in Springfield Township. Agents Chiofolo and Kimberlin and one other entered the appellant’s parked automobile. The appellant then drove away from the parking lot proceeding from a quarter to half mile down Highway 620. During this movement the appellant sold three pieces of paper each containing 100 “hits” of LSD to the agents for $650.00.

[1051]*1051The appellant was subsequently apprehended on 20 January 1975 at his quarters on the Fort Dix military reservation and was ultimately charged with possession and sale of LSD on the three occasions set forth above in violation of 21 U.S.C. § 844(a) as assimilated under Article 134, U.C.M.J. These offenses constitute the specifications of Charge I which are in issue before us.

Appellate defense counsel urge us to dismiss the charge and its specifications as the purported sales took place off post in Springfield Township, New Jersey and are therefore not “service connected.” Government counsel on the other hand urge that the purported sales had sufficient “service connection” to justify court-martial jurisdiction.

In O’Callahan v. Parker,1 the Supreme Court of the United States mandated that in order that a crime to be under military jurisdiction it must be “service connected,” lest “cases arising in the land or naval forces, or in the militia, when in actual service in time of war or public danger,” as used in the Fifth Amendment be expanded to deprive every member of the armed services of the benefits of an indictment by grand jury and a trial by a jury of his peers.

In Relford v. Commandant,2 the Supreme Court extracted from their O’Callahan decision a 12-part test to be used on an ad hoc case-by-case basis for determining whether an offense was service connected.3 In Rel-ford, supra, the Supreme Court stressed nine additional considerations.4 The Court [1052]*1052noted the implication in the O’Callahan decision, arising from its emphasis on the absence of service-connected elements there, that the presence of factors such as geographical and military relationships have important contrary significance.5 In Schlesinger v. Councilman, 420 U.S. 738, 95 S.Ct. 1300, 43 L.Ed.2d 591 (1975), the Supreme Court of the United States stated concerning the matter of jurisdiction of military courts, “The issue requires careful balancing of the Relford factors to determine whether the military interest in deterring the offense is distinct from and greater than that of civilian society, and whether the distinct military interest can be vindicated adequately in the civilian courts.”

It is therefore apparent that the Supreme Court refused to draw specific lines of demarcation as to what is or what is not an offense cognizable under military jurisdiction. In addition, it appears that the geographical boundary of a military post, camp or station will not necessarily limit military jurisdiction when offenses are committed at or near such installation and otherwise detrimentally impact upon the enumerated criteria which favor military jurisdiction cited by the Supreme Court of the United States in O’Callahan and Relford, supra6

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

Related

United States v. Petitti
14 M.J. 754 (U.S. Army Court of Military Review, 1982)
United States v. Earhart
14 M.J. 511 (U S Air Force Court of Military Review, 1982)
United States v. Mackey
7 M.J. 649 (U.S. Army Court of Military Review, 1979)
United States v. Stokes
6 M.J. 595 (U.S. Army Court of Military Review, 1978)
United States v. Kline
5 M.J. 578 (U.S. Army Court of Military Review, 1978)
United States v. Beckman
4 M.J. 814 (U.S. Army Court of Military Review, 1978)

Cite This Page — Counsel Stack

Bluebook (online)
2 M.J. 1049, 1976 CMR LEXIS 677, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-valles-santana-usarmymilrev-1976.