United States v. James

Private Angela James (defendant) was charged with writing checks without sufficient funds, disobeying the lawful command of a superior commissioned officer, and making false official statements to investigators. Prior to James’s trial by general court-martial, her defense counsel submitted a motion for a sanity board pursuant to Rule for Courts-Martial (RCM) 706. A sanity board is a formal inquiry into the mental condition of the accused conducted by one or more physicians or clinical psychologists. In support of the motion, James’s counsel argued that he had personally observed her behaving abnormally, that she was unable to respond coherently to his questions, and that she was incapable of making decisions regarding her defense. James was not granted a sanity board; instead, she was given a thirty-minute mental-status evaluation by a counselor who was not a physician or clinical psychologist. The counselor had never conducted a mental-status evaluation before and had not been advised of the specific concerns expressed by James’s counsel. After the evaluation, the counselor produced a single-page form report declaring James mentally competent to stand trial. The military judge accepted James’s guilty pleas with regard to the charges against her. James appealed, arguing that the military judge had erred by denying her a formal sanity board.