United States v. Vogan

32 M.J. 959, 1991 CMR LEXIS 751, 1991 WL 86850
CourtU.S. Army Court of Military Review
DecidedMay 23, 1991
DocketACMR 8903196
StatusPublished
Cited by2 cases

This text of 32 M.J. 959 (United States v. Vogan) 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. Vogan, 32 M.J. 959, 1991 CMR LEXIS 751, 1991 WL 86850 (usarmymilrev 1991).

Opinion

OPINION OF THE COURT

VARO, Judge:

Pursuant to his pleas,1 the appellant was convicted by a general court-martial composed of officer members of two specifications of larceny and four specifications of attempted larceny in violation of Articles 121 and 80, Uniform Code of Military Justice, 10 U.S.C. §§ 921 and 880 (1982). His approved sentence provides for confinement for eighteen months. At the time of his offenses and trial, the appellant was confined at the United States Disciplinary Barracks (USDB), serving a sentence from a prior general court-martial conviction.

The appellant’s offenses stem from a mail scheme in which he fraudulently solicited funds. The appellant wrote some letters which stated he was in jail and destitute, and then asked for money to help him buy gifts for his daughter’s birthday. He also wrote letters seeking compensation for alleged injuries he received from using various products (for example, a false claim for repairing a tooth broken by a rock found in a candy bar). Following receipt of allegations against the appellant, officials at the USDB placed him in “administrative [960]*960segregation pending investigation” (ASPI)2 on 29 July 1988. He remained in either the controlled ASPI or “administrative segregation” (AS) environment for 132 days. He was returned to his normal prisoner status on 8 December 1988. Although the USDB investigating personnel had most of the information necessary for the charges in this case by late September 1988, the investigation into the appellant’s activities remained open until 22 February 1989. This delay was caused by a separate investigation by the Federal Bureau of Investigation (FBI) regarding additional letters threatening product tampering. The FBI investigation revealed that the letters differed significantly in both style and purpose from those sent by the appellant, and that the appellant was not the author. On 9 June 1989, charges were preferred against the appellant for the letters which the USDB investigation determined were sent by him. The appellant was brought to trial on 24 August 1989.

At trial and before this court, the appellant asserts that the military judge erred in failing to grant the appellant’s motion to dismiss the charges due to violations of the appellant’s right to a speedy trial. The appellant’s assertions have two bases:

a. First, that his placement in ASPI status on 29 July 1988 constituted pretrial restraint or confinement under Rule for Courts-Martial 304(a), thus starting the speedy trial clock under Rule for Courts-Martial 707; and

b. Second, citing United States v. Honican, 27 M.J. 590 (A.C.M.R.1988) and United States v. Boden, 21 M.J. 916 (A.C.M.R.1986), even absent pretrial restraint or confinement, the appellant was denied a speedy trial because the government possessed “substantial information” upon which to base preferral of the charges in September 1988, but failed to prefer them until 9 June 1989.

We disagree with the appellant’s argument and hold he was not denied a speedy trial.

The case law cited by the appellant both at trial and on appeal deals solely with speedy trial issues related to pretrial confinement. The appellant places strong emphasis on this court’s “totality of conditions” factors set forth in United States v. Smith, 20 M.J. 528, 530 (A.C.M.R.1985), petition denied, 21 M.J. 169 (C.M.A.1985). In Smith, this court set forth the factors used to determine if restriction is tantamount to confinement. A review of the appellant’s prisoner status leads us to conclude that many of the Smith pretrial restraint factors cannot be applied to a prisoner already incarcerated. We have found no basis upon which to support the appellant’s argument that placement in ASPI is tantamount to “confinement within confinement” so as to trigger the speedy trial clock of Rule for Courts-Martial 707. We reject the argument that the appellant, who is already in confinement, could also be held in pretrial restriction tantamount to confinement.

Neither the appellant, nor the government, nor this court have found any military case regarding the applicability of Rules for Courts-Martial 304, 305, and 707 to post-trial confinees. Our review of the analysis of these rules leads to a general conclusion that these provisions do not apply to post-trial confinees. The analysis does include specific comments and case citations holding that correctional custody for unrelated offenses does not start the speedy trial clock,3 but these are not dis-positive of the appellant’s assertion. Although the appellant’s basic confinement status resulted from unrelated offenses, his argument before this court rests on the fact that his placement in ASPI was directly related to the offenses for which he was tried.

Several federal cases address the post-trial speedy trial question before us. In United States v. Mills, 641 F.2d 785 (9th Cir.1981), cert. denied, 454 U.S. 902, 102 [961]*961S.Ct. 409, 70 L.Ed.2d 221 (1981), the Ninth Circuit Court of Appeals noted that “[administrative segregation by the prison board [was] not an ‘arrest’ or ‘accusal’ for speedy trial purposes.” The Court cited its prior opinion in United States v. Clardy, 540 F.2d 439 (9th Cir.1976), cert. denied, 429 U.S. 963, 97 S.Ct. 391, 50 L.Ed.2d 331 (1976), cert. denied, 429 U.S. 963, 97 S.Ct. 391, 50 L.Ed.2d 331 (1976), which held that “the identifying indicia of an arrest are absent in the prison setting.” Mills, 641 F.2d at 787. Similarly, in United States v. Jackson, 781 F.2d 1114 (5th Cir.1986), the Fifth Circuit Court of Appeals, citing its prior determination in United States v. Blevins, 593 F.2d 646 (5th Cir.1979), concluded that:

prison segregation is not an ‘arrest’ as defined in the [Speedy Trial] Act. In this case, Jackson was already confined to prison under sentence for another offense. His administrative segregation after the incident that triggered this case can easily be justified on general security grounds and cannot be said to be an ‘arrest’.

Jackson, 781 F.2d at 1115.

While speedy trial issues under the Uniform Code of Military Justice are controlled by Rule for Courts-Martial 707 rather than the federal Speedy Trial Act,4 in the absence of military case precedent, we find federal case law persuasive in determining the issue at bar.

As in Mills and Jackson, the appellant was already confined for other offenses. We also note that in Mills the delay between placement in administrative segregation and trial was ten months. As in Mills, the appellant suffered no prejudice from any delay in preferring charges in this case. Barker v. Wingo, 407 U.S. 514

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Related

United States v. Vogan
35 M.J. 32 (United States Court of Military Appeals, 1992)

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Bluebook (online)
32 M.J. 959, 1991 CMR LEXIS 751, 1991 WL 86850, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-vogan-usarmymilrev-1991.