CORE CRIMINAL LAW SUBJECTS: Crimes: Article 80 - Attempts

2008 (Transition)

United States v. Mitchell, 66 M.J. 176 (appellant’s admissions during the providence inquiry that he believed the substance he sold was marijuana, but was later told that it was not marijuana, established all the elements of attempted distribution of marijuana). 

 

2001

United States v. Roeseler, 55 MJ 286 (attempted conspiracy to commit a crime under the Uniform Code of Military Justice is a military offense under Article 80, UCMJ).

(the offense of attempted conspiracy to murder fictitious persons did not require agreement or a shared intent among the expected conspirators with respect to the object of the alleged conspiracy; it was appellant’s belief or understanding that was critical to establish his guilt of this attempt offense).

(the military judge’s explanations of a charged conspiracy and a charged attempted conspiracy, taken together, were sufficient to inform appellant that conspiracy, unlike attempted conspiracy, required that the alleged conspirators actually share the same criminal intent or mental state).

(the defense of impossibility of the crime attempted or conspired is not a defense to a charge of attempt or conspiracy under military law; therefore, because the impossibility of the offenses is not a defense to either attempt or conspiracy, it is not a defense to the charge of attempted conspiracy).

(with respect to the offense of attempt under Article 80, an accused should be treated in accordance with the facts as he or she supposed them to be; "A person who purposely engages in conduct which would constitute an offense in the attendant circumstances were as that person believed them to be is guilty of an attempt" (para. 4c(3), Part IV, MCM, 1984)).

1999

United States v. Smith, 50 MJ 380 (where accused admits in providence inquiry that acts went beyond mere preparation and points to a particular action that satisfies himself on this point, it is neither legally nor logically well-founded to say that actions that may be ambiguous on this point fall short of the line “as a matter of law” so as to be substantially inconsistent with guilty plea).

(accused’s admissions during guilty plea inquiry, in their entirety, show substantial step toward commission of crime of larceny and are sufficient to constitute an attempt to commit larceny where:  (1) accused previously devised and executed a particular scheme to falsely obtain credit card from same bank and used it to make purchases; (2) accused provided co-actor unauthorized military personnel information with which to acquire second credit card from same bank; and (3) accused’s actions showed unequivocal criminal intent to commit larceny).


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