CORE CRIMINAL LAW SUBJECTS: Crimes: Article 134 -- Reckless Endangerment

2008 (September Term)

United States v. Thompson, 67 M.J. 106 (after finding the evidence of kidnapping factually and legally insufficient because the detention was de minimis, the CCA improperly substituted a conviction to reckless endangerment as an offense closely related to the offense of kidnapping, where a comparison of the elements of the two offenses revealed that a conviction for reckless endangerment required proof of elements that were not included in a specification for kidnapping, and reckless endangerment was not an offense necessarily included in the offense of kidnapping). 

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