United States v. Watkins

5 M.J. 606
CourtU.S. Army Court of Military Review
DecidedApril 17, 1978
DocketCM 436141
StatusPublished

This text of 5 M.J. 606 (United States v. Watkins) 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. Watkins, 5 M.J. 606 (usarmymilrev 1978).

Opinion

OPINION OF THE COURT

JONES, Senior Judge:

The appellant was convicted of attempting to transfer marihuana, possessing mari[607]*607huana (two specifications), transferring marihuana (two specifications), and breaking restriction in violation of Articles 80 and 134, Uniform Code of Military Justice, 10 U.S.C. §§ 880 and 934. He was sentenced to a dishonorable discharge, forfeiture of all pay and allowances, and confinement at hard labor for four years. The convening authority approved the sentence. We are reviewing the case pursuant to Article 66, UCMJ.

The Government concedes that the evidence is insufficient to support the charge of attempting to transfer marihuana and that the charge of breaking restriction was a minor offense improperly joined with the major drug offenses. We will dismiss those charges and take appropriate action on the sentence.

The appellant asks this Court to dismiss the charges of possession and transfer of marihuana, asserting that the Government failed to establish that the substance in each of the instances was marihuana. The prosecution sought to prove the identity of the substance through the testimony of witnesses familiar with marihuana and by submission of laboratory reports of analysis.

There were two instances of possession and transfer of marihuana occurring about ten days apart. On the first, the prosecution established its case through the testimony of the informant buyer who made the purchase and was familiar with marihuana, the testimony of another soldier who observed the transaction, the testimony of the criminal investigator who controlled the informant, the property receipt form (DA Form 4137) which established a chain of custody, the laboratory report form (CID Form 72-R) which showed the substance to be marihuana, and the marihuana itself. The same evidence was offered regarding the second incident with the exception of the testimony of an eyewitness, there being no eyewitness to the second transaction.

The defense offered no objection to the admissibility of the chain of custody form, the laboratory report, or the marihuana with regard to the first incident but objected to the documents and to the substance with regard to the second incident. The objection to the chain of custody form was based on the fact that the criminal investigator who identified the document was not the one who signed it (he typed it up and watched another agent sign it); objection to the lab report was based upon the alleged alteration of the document after its preparation; and objection to the marihuana was based upon the lack of an established chain of custody. The military judge overruled the objections and admitted the documents and the marihuana.

Before this Court the appellant has limited his argument to the admissibility of the lab reports. He argues that both were inadmissible because appellant was denied his Sixth Amendment right to confront the chemist who prepared the reports; that the lab reports did not qualify as business entry exceptions to the hearsay rule, as no foundation was laid for admissibility as such; and that the lab reports were made with a view to prosecution. No appellate argument has been made as to the admissibility of the chain of custody forms or the admissibility of the marihuana.

We find the admissibility of the lab report regarding the substance of the first transfer to be governed by United States v. Evans, 21 U.S.C.M.A. 579, 45 C.M.R. 353 (1972), and admissibility of the lab report on the substance of the second transfer to be governed by United States v. Nault, 4 M.J. 318 (C.M.A.1978).

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Related

United States v. Evans
21 C.M.A. 579 (United States Court of Military Appeals, 1972)
United States v. Burge
1 M.J. 408 (United States Court of Military Appeals, 1976)
United States v. Torrence
3 M.J. 804 (U S Coast Guard Court of Military Review, 1977)
United States v. Nault
4 M.J. 318 (United States Court of Military Appeals, 1978)

Cite This Page — Counsel Stack

Bluebook (online)
5 M.J. 606, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-watkins-usarmymilrev-1978.