United States v. Bryant

Army Private Angela Bryant (defendant) was a member of the 1st Armored Division while it was deployed to Saudi Arabia as part of Operation Desert Storm. A special court-martial was convened to try Bryant for disobeying orders, with the trial scheduled to occur at the division’s operating location in Saudi Arabia. Bryant’s trial attorney believed that the case against Bryant had problems and that she might receive an acquittal if she chose to have her case heard by a panel of court-martial members instead of the military judge. However, Bryant’s attorney also believed that the ground operations in Operation Desert Storm were about to begin at any moment, and that the military would operate better if members of the 1st Armored Division were at their ordinary duty stations instead of serving as court-martial members for Bryant’s trial. Feeling like he had conflicting duties to act in both the military’s best interests and Bryant’s best interests, Bryant’s attorney ultimately acted in what he believed were the military’s best interests, advising Bryant to request that the judge decide her case instead of a panel of members. Unaware of the attorney’s motivation, Bryant took his advice and requested that the military judge decide her case. The trial occurred on February 23, 1991. The next day, Desert Storm’s ground operations began, including operations conducted by the 1st Armored Division. Bryant was convicted by the military judge. During the appellate review of Bryant’s conviction, the trial attorney submitted an affidavit admitting that he had felt conflicted about who should decide Bryant’s case. Bryant relied on that affidavit to claim that her trial attorney had provided ineffective assistance of counsel during the pretrial phase of her court-martial proceedings.