2023 (October Term)
United States v. Grijalva, 84 M.J. 433 (the preemption doctrine generally prohibits using Articles 133 and 134, UCMJ, to charge conduct covered by Articles 80 through 132, UCMJ).
(the primary question in applying the preemption doctrine is whether Congress intended to limit prosecution for wrongful conduct within a particular area or field to offenses defined in specific articles of the UCMJ).