The Hasan sentencing hearing on aggravating and mitigating factors and other evidence got underway yesterday.  CNN (here), Austin americna Statesman (here, with updates from throughout the day), and the Kileen Daily Herald (here, including a complete list of the prosecution witnesses that testified yesterday).

AP via Yahoo News, here, has more on PFC Manning’s desire to become Chelsea Manning while incarcerated.

Sep. 2, 2014, that’s the date for the first capital trial  of a Gitmo detainee reports the Miami Herald here. Abd al Rahim al Nashiri will face charges stemming from the explosion that ripped through the USS COLE in October 2000.  The 9/11 conspirators’ case will begin Sep. 22, 2014 if prosecutors get their requested triaol date–which seems unlikely now that al Nashiri is set for 3 weeks earlier. 

This is an interesting case, Marine accidentally shoots tent mate in Iraq, [severely injures] him, isn’t charged, and gets an honorable discharge.  US Attorney hears about the case,  and files charges for assault and false statements.  The district court judge in the case is perplexed, as am I.  Why is it when the military wants a USAO to prosecute a case its a struggle to get resources, see e.g. Bob Reed and others testimony in 2008 here, but if they get a burr in their . . . .  NYT coverage here.  [My bad on the earlier report, not sure whyI wrote that he killed the guy]  H/t Navy JAG

29 Responses to “Military Justice News Aug. 27, 2013”

  1. Navy JAG says:

    The corpsman that was shot “survived, but was left partly blind.”

  2. Dew_Process says:

    @ the al Nashiri case – his “learned counsel,” Rick Kammen, Esq., is in the middle of a lengthy triple murder retrial that is projected to go through the week of 16 SEP 13.  While nothing surprises me anymore RE: GTMO, the defense is obviously going to need an adjournment.

  3. ExTC says:

    Hard to believe that the USMC would let this case go, all it ever took was five minutes of admin to put him on legal hold to resolve that aspect of the case. Absurd. I assume the USMC is so angry about the case the 92’s for dereliction are ready to preferred on the individuals who let him get out with an Honorable when seemingly they wanted to GCM him but couldn’t pull it off. 
    While not a fan of shooting a tent mate in Iraq or the jerks who dry fired others, not sure this is best handled in NYC. 
     

  4. ARMYTC says:

    Hasan did not question any witnesses and did not present any evidence. Sentencing Argument at 1000(central) tomorrow.

  5. ResIpsaLoquitur says:

    Sheesh, this really is becoming “suicide by court-martial.”  Does the judge have the ability to let Hasan’s fired military counsel present argument in an amicus capacity?  I’d be astonished if the panel gives anything other than death, but if someone did argue on his behalf and he did get something less than death, what’s his remedy if he appeals?

  6. stewie says:

    Arguably maybe vis-a-vis the military judge, but apparently that didn’t happen.  So if we are ok with it in this case, let’s make sure we are ok when someone decides to do it in a less inflammatory case.  I think the right answer is you assert the government’s interest in an adversarial process at the sentencing case of a capital court-martial and you let standby counsel do the sentencing if the accused refuses at least to present mitigation evidence.  It’s not like it would matter in this case, but it might in a future one.

  7. Joseph Wilkinson says:

    Something like that has been tried at the appellate level – I read this case from the Eleventh Circuit a long time ago. The appellant had been sentenced to death; state-appointed lawyers kept filing motions and habeas petitions for him; but he did not want any of that and in fact wanted to be executed. 
    In that context, if a lawyer I don’t want is appearing to present arguments and evidence I don’t want, he’s trying to appear as a “next friend” – and I have a right to refuse him and represent myself per Faretta v. California as long as I’m mentally competent. In fact, under Faretta (6-3 decision), that is a constitutional right I have, and I think your proposal would violate it.  (The case includes some interesting history on the question – it claims that in Anglo-American history, only the Court of Star Chamber forced sane people who were actually present to be represented against their wills.) 
    Claiming this lawyer as some kind of “trial-court amicus curiae” would be an unworkable legal fiction to get around this constitutional right and I think that argument would have to fail.

  8. stewie says:

    Faretta was a non-capital case. Death is different.  There are additional constitutional and societal concerns involved in capital sentencing.  Do you get to tell a state court that you don’t want mitigation material included in the pre-sentencing report? Nope. Do you get to waive your auto death penalty appeal in civilian courts? Nope, there’s case law that says you don’t. There’s a limit to the 6th Amendment, the question is: where.  I would argue this is an open question as there is case law on both sides concerning whether or not you can completely abdicate the adversarial process at a capital sentencing hearing.
    I don’t believe Faretta is binding precedent for a capital case.

  9. Bill Swinney says:

    I am coming at this from a layman’s perspective, so I would appreciate other commenters’ thoughts on this subject.  But I’m struggling with what the problem is here—once Major Hasan was found sane, why should it matter that he doesn’t want to contest the charges or death request? 

  10. stewie says:

    If this were a non-capital case, then we might say it doesn’t matter.  Faretta at least says as much.  But death cases are different.  It’s the ultimate punishment so we as society like to be really, really sure we’ve done everything to allow a jury/panel to reach the most correct result.  The way we do that is through not just an adversarial process but an extra-adversarial process with added protections and rights for the accused (at least at sentencing) with an eye towards giving them as much mitigating and extenuating evidence as reasonably possible.

  11. Joseph Wilkinson says:

    The Eleventh Circuit case I linked you to was a capital case (though obviously not Supreme Court) – they cited Faretta in passing.  The problem is, the Supreme Court held this to be a constitutional right the defendant has to choose to speak for himself – they noted in passing that only the much-denounced Court of Star Chamber forced people to be represented (at the trial level) if they didn’t want to be.
    What you’re proposing is to take away one of the defendant’s constitutional rights in death penalty cases “because death is different.”  I can’t see that argument working. 
    What you’re proposing is not really an “adversarial” system, but a paternalistic, semi-inquisitorial system, in which the government appoints a person who lacks standing to speak for the defendant to do so anyway.  Thus, government representatives would be deciding both prosecution and defense strategy.  That is not adversarial.

  12. stewie says:

    No, what I am proposing is that the constitutional right to self-representation is not unlimited and wholly unfettered.  For example, the right to represent oneself can be forfeited if an accused is disruptive which is noted in Faretta (in fact the right to be present at all can be taken away).  A trial can proceed as well post-arraignment if an accused is AWOL, and the attorney in that case has at least some ability to present mitigation evidence.
     
    The case you linked to was not about direct appeal, but habeas appeal.  There’s a difference.  In Martinez v. Court of Appeals of Cal, 4th District 528 US 152, the Supreme Court said that Faretta does not extend to direct appeals (and that was a non-capital case).  The Supremes said in Martinez that there is no constitutional right to self-representation on direct appeal.
     
    The case law is scattered.  Some courts have said there is no right to self-representation at capital sentencing and appointed counsel to present mitigation over the objection of the accused, others have mandated presentencing (with mitigation) reports for capital sentencing (e.g. Florida in Muhammad v. State).  Others have in fact said Faretta does apply to capital case (the 5th circuit) making your argument that the 6th Amendment right trumps all.  It’s in no way established either way, and again Faretta was not a capital case.  Until the Supremes speak directly on this point, it’s an open question with no consensus.
     
    I am not proposing a “semi-inquisitorial” system, what I am proposing is use of counsel, whether appointed, amicus, or standby, to present mitigation evidence.  That is in fact adversarial.  Just like on direct appeal, I am proposing there is a cutoff where the accused’s rights to self-representation is overborne by other constitutional (5th and 8th Amendments) and societal considerations.

  13. rob klant says:

    I like it:  you only get to die when we tell you you can die.

  14. ResIpsaLoquitur says:

    Yeah, I don’t really want paternalism.  If I were the judge, though, and the public and the prosecutor were both shouting for “death” with all their bloodlust, I’d want some kind of devil’s advocate (for want of a better term) to speak where no one else was willing to do so.  Isn’t there a legitimate concern that something might be missing but no one’s seeing it because the white whale is in their crosshairs?  The advocate wouldn’t even necessarily need to be overriding Hasan’s wishes, so much as giving the court an alternative viewpoint which is badly needed in a case where death is on the table.  I won’t lose much sleep over Hasan, but if there were–however implausible–some mistake being made in this case, then there’s no reversing it once Hasan is dead.
    I wish I had a concrete, historical example to illustrate this with.  I don’t.  The best I can come up with is a piece of fiction I read once.  This was in an Incredible Hulk comic, of all places, and the Hulk wasn’t even this issue.  The gist of the story was that a lady assassin killed a U.S. senator and roughed up his wife, and was executed for it to the delight of the public and the prosecutor.  She didn’t put on a defense for her actions (and her sanity plea was rejected).  After the execution, it turned out that the assassin was childhood friends with the senator’s wife.  Turned out that the senator had been beating his wife, who called her friend to take him out so that he’d stop doing it.  Would that have gotten her off the death penalty?  Who knows–it’s fiction–but in the real world, that probably would have been tremendous evidence in extenuation.  The killer took that information to her grave, though, to protect her buddy.
    Again, I admit that it’s fiction, and I can’t imagine anything plausibly close to that applying in Hasan’s case given what we know.  Still, I’ve always felt that one of the purposes of fiction is to get us thinking about issues that haven’t yet happened to us in real life.  If an accused is unwilling to speak for himself, then what information or argument have we not considered about them?  What are we not hearing that’s being otherwise drowned out by calls for death?  I think the court has an interest in having someone give a disinterested opinion about an accused even where the accused will not.

  15. rob klant says:

    So, like a “special victim counsel”, but for a pro se accused in a death penalty case?
    Personally, I’d prefer an honest, above-board “paternalism” (for lack of a better word).  I think it’s most consistent with the history of the military justice system, as I read it.

  16. stewie says:

    We already tell an accused he can’t plead guilty at a capital trial.

  17. Joseph Wilkinson says:

    I am proposing there is a cutoff where the accused’s rights to self-representation is overborne by other constitutional (5th and 8th Amendments) and societal considerations.
    This puzzles me.  I can’t see what the 8th Amendment has to do with it at all. If the death penalty per se is “cruel and unusual” then it’s forbidden, period, and no amount of “extra due process” makes it otherwise. 
    Whenever I see a case about “the defense, in the court’s judgment, didn’t put on enough of a case” – it’s always as “ineffective assistance” under the 6th Amendment.  (Unless thegovernment somehow prevented it, as by withholding Brady material, but this isn’t about the government standing in the way of a good defense.)  Has the 5th ever been read in this way?  (Not a rhetorical question.)
    Could someone like Hasan escape the “government busybody” by hiring a private counsel who agrees to present no case for him, or by doing a really short one just to avoid being spoken for?  Or would the government always have the final say as to whether he’d put on “enough” defense to satisfy them?
    RIL – Sounds like a good story and a poignant one; but if the killer was taking her secret to the grave to protect her friend, how would a government “amicus” lawyer find out about something like that to present it at trial?  Under those circumstances she wouldn’t tell her own lawyer, and would probably not be on speaking terms with a government busybody; and I assume this “standby” lawyer wouldn’t have his own investigative staff to go find out facts that the police didn’t.  

  18. ResIpsaLoquitur says:

    Rob,
    Well, an SVC is still representing somebody–the victim (purported or actual).  I’d think an amicus attorney would be representing, if anything, the justice system.  He or she wouldn’t even have to enter into an attorney-client relationship with the accused, particularly since somebody like Hasan wouldn’t want one anyway.
    Think of it this way–have you ever been 99% certain of a course of action, but you asked one of your subordinates to “argue with you”?  (Or conversely, has you boss ever said “argue with me”?)  Sometimes you just want that independent opinion to make sure you’re not missing something.
    Besides–I maintain my “what’s the harm?” position (constitutional violations notwithstanding).  If the court entertained an amicus argument and the accused did not get death, what’s his remedy?  A rehearing on sentencing so the panel can be persuaded to kill him anew?  What appellate court is going to allow that?

  19. ResIpsaLoquitur says:

    @Joseph Wilkerson–
    Point taken.  It was the best example I had available.  My larger point is that in a case where death is on the line, I wish somebody would speak in the accused’s favor even where the accused won’t, if only to save ourselves from our own bloodlust.  One of the elements of the story was the crowds outside the prison, partying and drinking been on the night of the execution.  It’s easy to get caught up in the desire to see someone pay when we think they’ve wronged us or society.   Or think of Henry Fonda’s character in Twelve Angry Men–the jury was ready to hang the defendant until his character said, “Hey, let’s look at the evidence before we do this.”  I’d hope that an amicus attorney could be that guy.

  20. Joseph Wilkinson says:

    RIL – now that I think of it I know one good fictional story that I think’s a little closer to the mark – Rumpole and the Golden Thread. The accused, a politician in a fictional African country, wants only a perfunctory defense so that he’ll be sentenced to death and his followers will rise in rebellion.  His wife, however, knows of alibi evidence that will save his life – and will embarrass him enough to prevent the revolution and kill his political career.  He himself absolutely objects to putting this evidence on, but of course his heroic defense attorney does so.

  21. Joseph Wilkinson says:

    (obviously, in that tale, if he’d gone without an attorney he’d’ve kept quiet; but an “amicus attorney” might’ve done otherwise.)

  22. stewie says:

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    “[T]he Eighth and Fourteenth Amendments cannot tolerate the infliction of a sentence of death under legal systems that permit this unique penalty to be so wantonly and so freakishly imposed.”Furman v. Georgia. 

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    Williams v. New York said that the fullest information about the accused’s life and characteristics is required.
    It’s not per se unconstitutional so long as relevant mitigation evidence is investigated and presented.  “[C]onsideration of [mitigation] evidence is a ‘constitutionally indispensable part of the process of inflicting the penalty of death.”  Cal v. Brown.

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    All of the seminal cases talk about due process (14th and 5th) and the 8th amendment.  The failure of the 6th amendment right leads to a deficiency in the process under those other amendments.
    As pointed out in another thread, Article 61 says you can’t waive appellate review in a capital court-martial. And we know that you can’t plead guilty at a capital trial.
    So I find it somewhat perplexing that you can have your 6th amendment rights overruled at the merits stage to do the most mitigating thing you can do (plead guilty) and you can have them overruled on appeal, but at sentencing it’s sacrosanct?

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  23. stewie says:

    oh goodness, what just happened?? Totally sorry for whatever I just screwed up.

  24. Joseph Wilkinson says:

    I quite agree that not letting a person plead guilty in a death case is a terrible idea, and I would like to see that one overturned as soon as possible on Sixth Amendment grounds, or repealed by Congress because it’s a plain bad idea.  (If they’re worried about a totally bogus confession in a capital case, let them require some government corroboration even in guilty plea cases – but let the man plead the way he wants to plead.)
     
    Furman doesn’t tell me much – the court just said that “the imposition and carrying out of the death penalty in these cases constitute cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments” – but not that the problem relates to representation or guilty pleas.  (And I read that this was the case that effectively outlawed the death penalty ’til the 80’s, though the court didn’t come out and say that)
     
    Your quote is from Justice Stewart’s concurrence, not the opinion of the court; and he seems to be arguing that the death penalty is unconstitutional because it’s done so rarely (there are lots of murders as bad as this; how come only some get the death penalty?), not that you need more advocacy for the accused to make it less cruel and unusual.  Arguably, by his reasoning any safeguard that made the death penalty rarer (such as adding an advocate for innocence when the accused didn’t want one) would make it more constitutionally questionable.
     
    Williams doesn’t deal with the Eighth Amendment at all – it’s pure due process – and as I understand the majority opinion, it refuses to impose a different standard for death cases:
     
    “It is urged, however, that we should draw a constitutional distinction as to the procedure for obtaining information when the death sentence is imposed.  We cannot accept the contention.”
     
    It doesn’t require the “fullest information about the accused’s life and characteristics.”  It just says the court is free to consider out-of-court information (such as affidavits in sentencing reports) on sentencing, whether the penalty is death or not.  So in that case at least, it seems that “death is not different.” 
    (It does contain a lot of language praising modern sentencing because it does bring in so much information to try to “make the punishment fit the offender, not just the crime,” but it does not say the Constitutional requires it, or particularly requires it for death cases.  Or so I’m reading it.)

  25. Joseph Wilkinson says:

    In fairness, California v. Brown pointed me to Lockett v. Ohio and Eddings v. Oklahoma, which I am reading to say that the defense may not be precluded from introducing a broad range of mitigating evidence in death cases — and cited the Eighth Amendment in their reasoning, aiming to avoid “capriciousness” in imposing the death penalty.  But this is still a far cry from requiring the defendant to “put on a defense,” or having a government busybody do it for him if he doesn’t want it.  
     
    I think the way out is to let the defendant plead guilty in death cases if he wants to, and get the benefit of mitigating his case that way (“At least I didn’t make excuses”) as opposed to having someone else pop in and make excuses for him.

  26. stewie says:

    You asked how the 8th amendment was relevant so I cited you several cases that said exactly that.  I also threw in cases that talked about DP i.e. the 14th or 5th As (thus Williams).  Now you say there is no case that “requires” except there are.  Most of them are at the state level particularly in NJ and CA where the courts had standby counsel do it.  Colorado has appointed amicus counsel to do it.  Some require mandatory presentencing reports in DP cases which include mitigation/extenuation like Florida. 
     
    You’ve presented this position as if it’s some crazy clearly rejected theory, and that’s pretty much dead wrong.  It is not only a commonly held position but there are plenty of cases that have upheld it, it simply hasn’t made it’s way up to the Supremes to weigh-in on between those courts have held this position and those that apply Faretta to capital sentencing (and those are no more voluminous).
     
    I’ve also shown that the Supremes (and someone else showed that the UCMJ) become “busybodys” on appeal as they can’t be waived in DP cases on direct appeal either in civilian court or in military court.
     
    It. Is. An. Open. Question.
    Again, we have plenty of examples of “government busybodys” on pleading guilty in the military and on waiver of appeal everywhere in capital cases, so explain to me again why sentencing alone is the one part that’s sacrosanct?
     
     

  27. Joseph Wilkinson says:

    It ought to be sacrosanct at pleading and trial as well – unless the person is insane or has forfeited his rights by running away or acting disruptive of something.  If the Supreme Court tests that “you can’t plead guilty” business I hope they overturn it, and I am not going to answer for a policy I find repugnant like that one.  Thus, I will not “explain again” what I never said, and do not believe, in the first place.
    (You will notice, however, that Hasan was allowed to present no evidence on findings — while he had to plead not guilty he did not have to present a case at trial, and indeed he did not, so it’s not correct that this is “only at sentencing” even under the current system.)
     
    You presented this as (I’m paraphrasing) “the sixth amendment says he can speak for himself (per Faretta), but the fifth and eighth amendments cut against that.”  And I asked “how does the eighth amendment do that?”  You haven’t shown how.  You’ve cited:
     
    (1) A case that says “the death penalty is cruel and unusual as applied in these cases” without explaining why (Furman);
    (2) A case that says “the court can consider out-of-court evidence in death cases, just as they do in other cases” (Williams); and
    (3) A case that says “the defendant, himself or through counsel, can present a broad range of sentencing evidence in death cases, and the government can’t stop him — but the judge can still tell the jury not to be moved by mere sentiment or public opinion”  (Brown, citing Lockett and Eddings).   When I looked at Lockett and Eddings those at least showed me how the 8th Amendment has something to do with death cases without simply forbidding it. But…
     
    …not one of these cases says, or even begins to say, or shows the beginning of how you’d begin to say, “the Eighth Amendment requires mitigating evidence to be presented over the defendant’s objection,” which is the position I am arguing against.  If there are “plenty of” cases that say it, I’d be genuinely interested to read one or two of them and see how they reason it.  I don’t care if it’s a “common” view; I want to know how it’s reasoned, beyond “it’s death and death is different.”
     
    The Eleventh Circuit habeas case I linked to before shows where that road leads…a sane man who does not want to challenge his conviction being “represented” by busybody lawyers whom he does not want, and who keep arguing that he is not sane and can’t speak for himself, after eight or more psych evals have said he can.  The opposite of the adversarial system; a pure inquisitorial/paternalistic system where “if you don’t say what the state wants to hear, then the state will speak for you.” 

  28. stewie says:

    I dont know how much clearer to cite it other than doing a dissertation on all of the case law.  It’s not a difficult concept and it’s puzzling to me why you continue to suggest that you dont understand how the 8th and 5th amendment could cut against it.  I could understand if you said I see it, but I still think the 6th is paramount.
     
    I cited more than those three cases, I cited Hitchcock v. Dugger, I cited Brown which says more than what you cited, a lot more.  I cited Muhammad which involve a member of the court putting forward mitigation evidence in a presentencing report over the accused’s objections.  But you want more? People v. Chadd is a Cal Sup Ct Case, take five minutes and look at NJ death penalty law in this area there are a plethora of cases there as NJ has a lot of case law directly on point in this area Koedatich is a good place to start, GA has a case that talks about this, CO, CA has multiple Sup Ct cases both for and against on this (another state that has had a lot of cases on this subject).
    Ya know, I didn’t just germinate this in my own mind.  I contributed not one whit of original thought to this concept, smarter folks than me came up with this from before I was a gleam in my law professor’s eye. 
     
    You clearly don’t like the idea that “death is different” but that’s pretty standard and common and accepted in capital jurisprudence so despite your clear disdain for the concept, it’s an acceptable and accepted frame both in civilian and military capital case law, and the 8th and 5th Amendment are part of that.
    I dont think being allowed to present no evidence and not being allowed to plead guilty are functional equivalents…one is mitigating, the other is neutral.  One gives full rights to the accused, one does not. So no, not wrong.
    Same with appeals, not allowing someone to waive their appeals is not the same as not requiring any evidence to be presented at appeal.
    I dont know what else to say to you.  I’m perplexed not at your disagreement with the concept, because several courts agree with you, but at your wholesale disavowal of the very notion that the concept exists or what it is based on.

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