United States v. Steele
United States Court of Appeals for the Armed Forces
53 M.J. 274 (2000)
- Written by Salina Kennedy, JD
Facts
Lance Corporal Milton D. Steele (defendant) was convicted of drug charges by a general court-martial, and his conviction was affirmed by the Navy-Marine Corps Court of Criminal Appeals. Steele was represented during his court-martial by a military attorney and by Mr. C., a civilian defense attorney. Mr. C was licensed to practice law in Iowa, Hawaii, and Texas, but his bar membership in each of these jurisdictions was on inactive status at the time of the court-martial. Steele appealed to the United States Court of Appeals for the Armed Forces, arguing that he had been deprived of his Sixth Amendment right to effective assistance of counsel because Mr. C’s inactive bar status had disqualified him from representing Steele at his court-martial.
Rule of Law
Issue
Holding and Reasoning (Effron, J.)
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