United States v. WILLIAMS

CourtNavy-Marine Corps Court of Criminal Appeals
DecidedApril 28, 2026
Docket202400331
StatusPublished

This text of United States v. WILLIAMS (United States v. WILLIAMS) 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. WILLIAMS, (N.M. 2026).

Opinion

This opinion is subject to administrative correction before final disposition.

Before DALY, HARRELL, and KORN Appellate Military Judges

_________________________

UNITED STATES Appellee

v.

Troy K. WILLIAMS Staff Sergeant (E-6), U.S. Marine Corps Appellant

No. 202400331

Decided: 28 April 2026

Appeal from the United States Navy-Marine Corps Trial Judiciary

Military Judges: Adam Subervi (arraignment) Benjamin B. Garcia (motions and trial)

Sentence adjudged 15 March 2024 by a general court-martial tried at Marine Corps Air Station Iwakuni, Japan. Sentence in the Entry of Judgment: confinement for three months, restriction to base for two months, and hard labor without confinement for three months.

For Appellant: Captain Arthur L. Gaston III, JAGC, USN (on brief) Captain Kyle W. Rodewald, USMC (argued) United States v. Williams, NMCCA No. 202400331 Opinion of the Court

For Appellee: Lieutenant K. Matthew Parker, JAGC, USN (on brief) Captain Jacob R. Carmin, USMC (argued)

Amicus Curiae for Appellant: Charlton J. Meginley, John C. Phillips, Andrey A. Loria Calvo, Lillian K. Thomas, Brittany E. White (on brief) Madison T. Keyser (argued)

Amicus Curiae for Appellee: Charlton J. Meginley, John C. Phillips, Connor J. Hebert, Reed M. Renfrow, Kyle M. Savoy (on brief) Captain Kurt S. Ebert, USMC (argued)

Judge KORN delivered the opinion of the Court, in which Chief Judge DALY and Senior Judge HARRELL joined. 1

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

KORN, Judge: A general court-martial composed of members with enlisted representation convicted Appellant of one specification of communicating a threat and one specification of domestic violence in violation of Articles 115 and 128b, Uniform Code of Military Justice (UCMJ). 2 Appellant was found not guilty of seven other specifications of domestic violence. The members sentenced Appellant to confinement for three months, restriction to base for two months, and hard labor without confinement for three months.

1 We held oral argument on 18 March 2026 at The Louisiana State University Paul

M. Hebert Law Center as part of the Court’s outreach program. We are extremely ap- preciative of the law school graciously hosting and organizing this event. We further commend the efforts of the students at the Veterans Law Clinic, under the supervision of Professors Charlton J. Meginley and John C. Phillips, for their highly professional and effective briefs and outstanding oral arguments. 2 10 U.S.C. §§ 915, 928b.

2 United States v. Williams, NMCCA No. 202400331 Opinion of the Court

Appellant raises four assignments of error (AOE), which we renumber as follows: I. Whether the military judge abused his discretion in ad- mitting hearsay under the residual hearsay exception, Military Rule of Evidence (Mil. R. Evid.) 807. II. Whether the military judge abused his discretion in admitting excerpts of the complaining witness’s inter- view with NCIS under Mil. R. Evid. 801(d)(1)(B)(i) despite finding she made the statements after her motive to fab- ricate arose. III. Whether this Court can conduct a factual sufficiency review where the members returned ambiguous findings. IV. Whether the evidence is factually sufficient to sustain Appellant’s conviction for domestic violence. We find no prejudicial error and affirm the findings and sentence.

I. BACKGROUND

Appellant was convicted of domestic violence by committing a violent of- fense against his wife, Dee, 3 and of communicating a threat by threatening to kill her. These convictions stemmed from an incident where Appellant became angry that his children were being too loud, and he felt that Dee was not doing enough to quiet them. Appellant eventually grabbed Dee and put his hands around her neck and over her mouth, then threatened to kill her. Two of their children, Sierra and Alice, witnessed this incident. At trial, Dee testified about the event in question and other charged mis- conduct. Defense counsel then cross-examined her about her motivations for testifying against Appellant, suggesting that she lied to gain leverage in a di- vorce and child custody proceeding. Following this cross-examination, the Gov- ernment offered portions of Dee’s interview with the Naval Criminal Investi- gative Service (NCIS) as prior consistent statements. The military judge ad- mitted this evidence, over Defense objection, under Mil. R. Evid.

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

are pseudonyms.

3 United States v. Williams, NMCCA No. 202400331 Opinion of the Court

801(d)(1)(B)(i), finding that “it serves to rebut the implied charge” that her tes- timony was based on “the risk and danger to her custody of her children, to her other outcomes in the divorce proceedings such as alimony and child support.” 4 The Government called both Sierra and Alice to testify at trial. Both chil- dren had great difficulty recalling the events in question, but Alice was able to recall a bit more than her sibling, describing Appellant putting his hand around Dee’s neck. 5 After Sierra’s and Alice’s testimony, the Government moved to introduce their recorded child forensic interviews (CFI) into evidence under Mil. R. Evid. 807, the residual hearsay exception, to prove that Appel- lant assaulted his wife and threatened to kill her. Appellant objected to this evidence, and the military judge sustained the objection to Sierra’s CFI but overruled the objection to Alice’s. He found that Alice’s CFI, which occurred when she was four years old, “is more probative of the point that’s offered than any other evidence that the proponent can obtain by reasonable efforts.” 6

II. DISCUSSION

A. The military judge abused his discretion when he admitted testi- mony under Mil. R. Evid. 807, but Appellant suffered no prejudice. 1. Standard of Review Rulings to admit evidence are reviewed for an abuse of discretion. 7 It is an abuse of discretion when the military judge (1) predicates a ruling on findings of fact that are not supported by the evidence; (2) uses incorrect legal princi- ples; (3) applies correct legal principles to the facts in a way that is clearly unreasonable; or (4) fails to consider important facts. 8 2. Analysis Mil. R. Evid. 807 is titled “residual exception.” It allows for the admissibil- ity of hearsay statements “in rare circumstances” 9 when:

4 R. at 1188.

5 R. at 1290.

6 R. at 1316.

7 United States v. Humpherys, 57 M.J. 83, 90 (C.A.A.F. 2002) (citing United States

v. Ayala, 43 M.J. 296, 298 (C.A.A.F. 1995)). 8 United States v. Rudometkin, 82 M.J. 396, 401 (C.A.A.F. 2022).

9 United States v. Czachorowski, 66 M.J. 432, 435 (C.A.A.F. 2008).

4 United States v. Williams, NMCCA No. 202400331 Opinion of the Court

(1) the statement is supported by sufficient guarantees of trust- worthiness—after considering the totality of the circumstances un- der which it is made and evidence, if any, corroborating the state- ment; and (2) the statement is more probative on the point for which it was offered than any other evidence that the proponent can obtain through reasonable efforts. 10 The Government offered Alice’s CFI for two reasons: (1) “to prove the ma- terial facts surrounding the charged conduct that occurred on 31 January 2023, specifically that [Appellant] did put his hand around [Dee’s] throat and over [her] mouth and that he stated he wanted to kill . . . [Dee];” 11 and (2) because the CFI “provides in more detail the particularity for which [Alice] . . .

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