United States v. WATLINGTON

CourtNavy-Marine Corps Court of Criminal Appeals
DecidedOctober 6, 2023
Docket202200076
StatusPublished

This text of United States v. WATLINGTON (United States v. WATLINGTON) is published on Counsel Stack Legal Research, covering Navy-Marine Corps 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. WATLINGTON, (N.M. 2023).

Opinion

This opinion is subject to administrative correction before final disposition.

Before HOLIFIELD, HACKEL, and DALY Appellate Military Judges

_________________________

UNITED STATES Appellee

v.

Cody B. WATLINGTON Machinist Mate (Nuclear) Third Class (E-4), U.S. Navy Appellant

No. 202200076

Decided: 6 October 2023

Appeal from the United States Navy-Marine Corps Trial Judiciary

Military Judges: Eric A. Catto (arraignment) Kimberly J. Kelly (trial)

Sentence adjudged 2 December 2021 by a general court-martial con- vened at Naval Station Mayport, Florida, consisting of officer and en- listed members. Sentence in the Entry of Judgment: confinement for two years and a bad-conduct discharge.

For Appellant: Lieutenant Aiden J. Stark, JAGC, USN

For Appellee: Lieutenant Michael A. Tuosto, JAGC, USN Lieutenant Colonel James A. Burkart, USMC United States v. Watlington, NMCCA No. 202200076 Opinion of the Court

Chief Judge HOLIFIELD delivered the opinion of the Court, in which Senior Judge HACKEL and Judge DALY joined.

This opinion does not serve as binding precedent, but may be cited as persuasive authority under NMCCA Rule of Appellate Procedure 30.2.

HOLIFIELD, Chief Judge: A panel of officer and enlisted members convicted Appellant, contrary to his pleas, of one specification of involuntary manslaughter by culpable negli- gence in violation of Article 119, Uniform Code of Military Justice [UCMJ], for negligently shooting a fellow Sailor in the chest resulting in his death. 1 Appel- lant was also found guilty of negligent homicide in violation of Article 134, UCMJ, for the same acts. 2 The military judge conditionally dismissed Appel- lant’s negligent homicide conviction and Appellant was sentenced only for in- voluntary manslaughter. Appellant asserts eight assignments of error [AOEs] which we reorder as follows: (1) the evidence is legally and factually insufficient to support the guilty findings; (2) trial counsel was disqualified because he was an accuser; (3) Director, Naval Reactors engaged in unlawful command influence [UCI] when he forwarded the charges to a subordinate commander and said he would fund the trial; (4) trial counsel committed prosecutorial misconduct; (5) the military judge abused her discretion by denying Appellant’s requested instruc- tion on the issue of culpable negligence; (6) the military judge abused her dis- cretion by allowing the victim’s brother to make an unsworn victim impact statement; (7) a bad-conduct discharge was inappropriately severe; and (8) Ap- pellant was entitled to a unanimous verdict. We find no prejudicial error and affirm. 3

1 10 U.S.C. § 919.

2 10 U.S.C. § 934.

3 We have reviewed Appellant’s fifth, sixth, and eighth AOEs and find them to be

without merit. United States v. Matias, 25 M.J. 356, 363 (C.M.A. 1987).

2 United States v. Watlington, NMCCA No. 202200076 Opinion of the Court

I. BACKGROUND

1. The Shooting Appellant and Machinist Mate (Nuclear) Third Class [MMN3] Hotel were friends who lived together with four other Sailors in Charleston, South Caro- lina, where they attended nuclear power school. 4 Many of these Sailors, includ- ing Appellant and MMN3 Hotel, owned and were experienced with firearms. On the evening of 7 April 2020, Appellant was handling a Beretta APX pistol that he had recently purchased. He removed the loaded magazine, then repeatedly pulled back the slide and released it. After doing this several times, Appellant inserted a loaded magazine, laid the gun on the living room table, and walked away. Appellant had recently learned there were two ways to field strip the Beretta APX. 5 Either method first involves removing the magazine and clear- ing the chamber of any ammunition. For the Beretta APX, one then (1) retracts the slide slightly, (2) presses the striker deactivation button on the right side of the firearm (resulting in a click indicating that the striker has been re- leased), and (3) presses the takedown lever on the right side of the weapon and rotates the lever down 90 degrees, at which point the slide can be removed from the frame. 6 The second method of field stripping the Beretta APX is similar, but instead of pressing the striker deactivation button, one pulls the trigger before rotating the takedown lever and removing the slide. 7 Intending to demonstrate this second method to MMN3 Hotel, Appellant picked up his firearm from where he had left it a few minutes before and at- tempted to remove the slide using the trigger-pull method. Appellant did not remove the magazine before doing so, nor did he clear the chamber. Appellant stood over MMN3 Hotel with the plan on removing the slide and letting it drop into his friend’s lap.

4 All names in this opinion, other than those of Appellant, the judges, and counsel,

are pseudonyms. 5 Field stripping is separating the slide and its components from the frame of the

firearm in order to clean and maintain it. R. at 755. 6 R. at 755-56.

7 R. at 756.

3 United States v. Watlington, NMCCA No. 202200076 Opinion of the Court

When his initial attempt to remove the slide did not work, Appellant racked the slide—chambering a round—and again attempted to remove the slide us- ing the trigger-pull method. He did this while pointing the gun at his friend. This time, when he pulled the trigger, he fired a bullet into MMN3 Hotel’s chest, killing him.

2. The Preferral and Referral Process 8 In August 2020, Legalman First Class [LN1] Foxtrot was assigned to Re- gion Legal Service Office Southeast [RLSO SE]. Following normal practice, one of RLSO SE’s trial counsel asked LN1 Foxtrot if he was willing to review the investigation and prefer the proposed charges if he agreed there was probable cause to support them. When LN1 Foxtrot agreed, he was given a “proposed charge sheet” and “written materials” regarding the case. 9 These materials in- cluded “a preliminary investigation, . . . a 70-page Naval Criminal Investiga- tive Service [NCIS] Report of Investigation [ROI], including a police report and summaries of interviews of [Appellant] and witnesses to the shooting.” 10 After reviewing the evidence, LN1 Foxtrot told the trial counsel that, un- less there was any other evidence to review, he was ready to prefer charges. 11 He then preferred the charges on 31 August 2020. During a subsequent Article 39(a), UCMJ, hearing, LN1 Foxtrot testified that, “[a]t the time of preferral, [he] understood his obligations as accuser [in- cluded] reviewing the proposed charge sheet and the supporting evidence and deciding whether or not the proposed charges were supported by probable cause. He erroneously understood probable cause to mean proof beyond a rea- sonable doubt.” 12 He also “understood that he could refuse to prefer the pro- posed charges if not supported by probable cause and felt comfortable in doing

8 The description of events in this section are taken from the military judge’s find-

ings of fact in her ruling denying the Defense’s motion to disqualify trial counsel and motion to dismiss for improper preferral, forwarding and referral. App. Ex. IX. We adopt these findings of fact as they accurately reflect the record. 9 App. Ex. IX, at 2. The proposed charge sheet included charges under Articles 118,

UCMJ (murder while engaging in an act inherently dangerous to another) and 119, UCMJ (involuntary manslaughter – culpable negligence). 10 U.S.C. §§ 918, 919. 10 App. Ex. IX, at 2.

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