ACCA posted this brief per curiam opinion on its web site today. United States v. Hudgins, __ M.J. __, No. ARMY 20090737 (A. Ct. Crim. App. March 25, 2010) (per curiam).
The addendum SJAR in the case was signed by the deputy SJA. ACCA held that this “constitutes error.” Id., slip op. at 2. ACCA declined to apply waiver because “appellant did not have the opportunity to comment on the error in his post-trial submission,” since the error occurred in the addendum rather than the original SJAR. Id. But ACCA declined to grant relief, concluding that there was no prejudice. Id., slip op. at 3.