CORE CRIMINAL LAW SUBJECTS: Crimes: Article 134 -- Assault, Indecent

2008 (Transition)

United States v. Mitchell, 66 M.J. 176 (the intent element of indecent assault may be satisfied, in the case of an accomplice, by proof that the accomplice shared in the perpetrator’s criminal purpose and intended to facilitate the intent of the perpetrator with respect to the commission of the offense; when an accused pleads guilty to aiding and abetting an indecent assault, the accused must admit to sharing in the perpetrator’s criminal intent to gratify the lust or sexual desires of the perpetrator; the accused’s admissions must objectively support a military judge’s finding that:  (1) the accused possessed the specific intent to facilitate the commission of the indecent assault; (2) the accused had a guilty knowledge; (3) the indecent assault was being committed by someone; and (4) the accused assisted or participated in the commission of the indecent assault). 

 

(in this case, appellant’s pleas of guilty to committing an indecent assault, by aiding and abetting a fellow Marine to have sexual intercourse with the victim was provident, despite appellant’s objection that the plea inquiry did not demonstrate that he acted with the specific intent to gratify his own lust or sexual desire; appellant admitted that he acted with the specific intent to gratify the perpetrator’s lust or sexual desires; in addition, appellant admitted that he intended to facilitate the perpetrator’s commission of the indecent assault, knew that the perpetrator had indecently assaulted the victim, and encouraged the perpetrator’s commission of the indecent assault; the military judge was not required to elicit facts from appellant demonstrating that he intended to gratify his own lust or sexual desires). 

 

2000

United States v. Ayers, 54 MJ 85 (evidence was legally insufficient to show that alleged victim of indecent assaults did not consent where:  (1) she knew the appellant was being flirtatious; (2) she invited herself to a movie in the day room, sneaked out of her barracks room, and voluntarily followed appellant into a conference room; (3) she admitted that she was interested in and infatuated with appellant; (4) she admitted she was a willing participant; (5) she once waited for appellant to return when he left briefly; (6) she cooperated with appellant’s instructions as he began to massage her; (7) she stated that she did not consider the acts an assault or rape; (8) she called appellant and talked to him several times over the following few days; (9) she voluntarily met with him again; (10) she did not report the incident until summoned to the commander’s office; and (11) her testimony, in sum, was that there was no unwanted sexual touching).



Home Page |  Opinions & Digest  |  Daily Journal  |  Scheduled Hearings  |  Search Site