United States v. Baldwin

54 M.J. 308 (2001)

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United States v. Baldwin

United States Court of Appeals for the Armed Forces
54 M.J. 308 (2001)

Facts

Captain Holly Baldwin (defendant) was tried by court-martial for offenses including larceny, mail tampering, and obstruction of justice. The panel hearing for Baldwin’s case consisted entirely of officers. Before Baldwin’s court-martial, she and other officers, including those on her panel, attended a mandatory command meeting. During this meeting, the attendees were told that court-martial sentences were too lenient, that officers should always be punished more harshly than enlisted soldiers, and that the minimum court-martial sentence should be one year. On the last day of Baldwin’s court-martial, Baldwin and the officers on her panel were required to attend another mandatory command meeting, causing a delay in Baldwin’s trial. The meeting again focused on overly lenient court-martial sentences. After the meeting, Baldwin’s court-martial reconvened, and she was convicted and sentenced to dismissal, a one-year confinement, and total forfeiture of pay and allowances. The convening authority approved the sentence, and the Army Court of Criminal Appeals affirmed. Nine months later, Baldwin submitted a statement to the Court of Criminal Appeals. The statement included details of the statements made at the two command meetings and alleged that the meetings had constituted unlawful command influence over Baldwin’s court-martial. The United States government (plaintiff) asserted that Baldwin’s claim lacked merit. The Court of Criminal Appeals summarily affirmed Baldwin’s sentence.

Rule of Law

Issue

Holding and Reasoning (Sullivan, J.)

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