MILITARY JUSTICE PERSONNEL: Military Judge: General Powers

2007


United States v. Harrow, 65 M.J. 190 (the military judge is permitted in a borderline guilty plea case to give weight to the defense evaluation of the evidence). 

 

United States v. Carruthers, 64 M.J. 340 (the exposure of a witness’s motivation in testifying is a proper and important function of the constitutionally protected right of cross-examination; however, the Confrontation Clause of the Sixth Amendment does not prevent a trial judge from imposing any limits on a defense counsel’s inquiry into the potential bias of a prosecution witness; trial judges retain wide latitude insofar as the Confrontation Clause is concerned to impose reasonable limits on such cross-examination based on concerns about, among other things, harassment, prejudice, confusion of the issues, the witness’s safety, or interrogation that is repetitive or only marginally relevant; the judge may restrict cross-examination when the probative value of the evidence sought would be substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the members).

 

United States v. Green, 64 M.J. 289 (in a bench trial, a military judge is not precluded from setting forth his reasons for the sentence imposed).

 

(a military judge may not interject his or her personal beliefs into the sentencing process).

2005


United States v. Deisher
, 61 M.J. 313 (when a servicemember is charged with violation of a lawful order, the legality of the order is an issue of law that must be decided by the military judge, not the court-martial panel). 


(the lawfulness of an order, like other issues of law, may involve questions of fact that must be addressed by the military judge for the limited purpose of resolving the issue of law; the consideration of such factual matters by the military judge in the course of addressing an issue of law is distinct from, and does not preempt, the responsibility of a court-martial panel to address factual matters pertinent to the elements of an offense in the course of returning findings on the issue of guilt or innocence). 


(when the defense moves to dismiss a charge on the grounds that the alleged order was not lawful, the military judge must determine whether there is an adequate factual basis for the allegation that the order was lawful; in the course of acting on such a motion, if the military judge rules that a specific set of words would constitute a lawful order under a specific set of circumstances, that is a preliminary ruling; the military judge’s ruling does not relieve the prosecution of the responsibility during its case-in-chief of proving beyond a reasonable doubt the facts necessary to establish the elements of the offense).  


(the lawfulness of an order is not an element, but is an issue of law to be resolved by the military judge, not members; in this case, the military judge committed prejudicial error in ruling on the motion to dismiss by treating both the issue of lawfulness and the predicate factual aspects of the lawfulness issue as matters to be resolved by the members and by submitting the issue of lawfulness to the members). 


2002

United States v. Quintanilla, 56 MJ 37 (a military judge does not exercise general jurisdiction over cases arising under the UCMJ; a military judge may exercise authority only over the specific case to which he or she has been detailed).

(a military judge may issue a warrant of attachment to compel the presence of a civilian witness, but only under very specific circumstances as set forth in RCM 703(e)(2)(G)(ii); military judges do not have the power to treat non-compliance with a subpoena as a contempt of court).

United States v. Humpherys, 57 MJ 83 (military judges possess ample authority to protect the attorney-client relationship during consideration of disqualification motions, including the power to examine evidence in camera, seal records of any Article 39(a) sessions, exclude unnecessary persons from hearings, and issue protective orders).

2001

United States v. New, 55 MJ 95 (by both the Code and the Manual, the military judge shall rule upon all questions of law and all interlocutory questions arising during the proceedings).

United States v. Anderson, 55 MJ 198 (military judge lacks inherent power to compel a victim to undergo nonconsensual examination, but the military judge and a trial counsel can use the persuasive powers of their offices to secure the witness’ consent to such examination).

1999

United States v. Gray, 51 MJ 1 (rejecting claim that military capital sentencing procedure is unconstitutional because the military judge lacks the power to adjust or suspend a sentence of death that is improperly imposed; see United States v. Loving, 41 MJ 213, 297 (1994), aff’d on other grounds, 517 U.S. 748 (1996)).

United States v. Biagase, 50 MJ 143 (a military judge, as the “last sentinel” to protect a court-martial from the effects of unlawful command influence, can intervene and protect the proceedings).

United States v. Roth, 52 MJ 187 (sequestration and sanctions for violations of a sequestration order are matters within the discretion of the court, and such matters will be reviewed on appeal under an abuse of discretion standard).

(MRE 615 dealing with exclusion of witnesses from the court room is a rule of evidence which may be relaxed during the sentencing portion of the trial).

(the ultimate sanction of excluding a witness’s testimony should be used ordinarily to punish intentional or willful disobedience of the military judge’s sequestration orders).


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