Courthouse Steps Decision Teleforum: United States v. Briggs

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Dean Reuter:  Welcome to Teleforum, a podcast of The Federalist Society's practice groups. I’m Dean Reuter, Vice President, General Counsel, and Director of Practice Groups at The Federalist Society. For exclusive access to live recordings of practice group teleforum calls, become a Federalist Society member today at fedsoc.org.

 

 

Nick Marr:  Welcome, everyone, to The Federalist Society’s Teleforum conference call, and this afternoon, December 15, 2020, we have a special Courthouse Steps Decision Teleforum on United States v. Briggs. I’m Nick Marr, Assistant Director of Practice Groups at The Federalist Society.

 

As always, please note that expressions of opinion on today’s call are those of our experts.

 

We’re very fortunate to have with us two experts who covered the oral arguments in this case just about a month or two ago. Our first guest today is Arthur Rizer. He’s director of Criminal Justice & Civil Liberties and Resident Senior Fellow at the R Street Institute. We’re also joined by Professor Richard Sala. He’s Assistant Professor of law at Vermont Law School. After Arthur and Professor Sala give their remarks, covering the case, we’ll open up the floor to audience questions, so we’ll be looking to you at that time. All right, without much more delay, Professor Sala, thanks for being with us, and I’ll hand the floor off to you.

 

Prof. Richard Sala:  Thank you so much. Thank you for the introduction, and I’m just going to get us started by just recapping United Sates v. Briggs. So United States v. Briggs is consolidated with United States v. Collins and United States v. Humphrey Daniels. And in each of these cases, a military member, in this case from the United States Air Force, is accused, tried, and convicted of rape at general courts-martial. Each of the trials takes place well after the rape occurred, ranging between 8 years and 17 years after the rape occurred, and really to understand how we get to United States v. Briggs, we have to take a brief look back to a 2018 case, United States v. Mangahas.

 

Mangahas was 2015 prosecution of a rape that was committed in 1997, and it was appealed to the Court of Appeals for the Armed Forces. It was appealed to CAAF, and, in that case, CAAF decides that Coker v. Georgia is applicable in the military context, and this becomes significant because Congress had devised a framework in the Uniform Code where all crimes punishable by a death could be prosecuted at any time, and all other crimes with an exception are going to be subject to a five-year statute of limitations.

 

After Mangahas, even though the Uniform Code of Military Justice says rape’s punishable by death, it’s essentially discounted under the theory of that because you can’t, as a result of Coker v. Georgia, employ the death penalty as a punishment for rape. The time-bar reverts to that five-year statute of limitations. And so let me very briefly work through the Uniform Code.

 

So Article 18 of the Uniform Code gives general courts-martial jurisdiction over individuals that are subject to the code for Uniform Code of military justice offenses, which include the crimes “punishable by death” when it’s specifically authorized by the code. Article 43 sets out the statute of limitations, and, as I said earlier, the statute of limitation offenses “punishable by death” can be tried and punished at any time, and then everything else is essentially subject to that five-year statute of limitations.

 

Finally, we look to the punitive article, which is Article 120. It’s the rape offense, which specifically states that it shall be punished by death or such other punishment as the court-martial may direct. And so, again, the upshot of the Court of Appeal for the Armed Forces’ decision in Mangahas is that the rape prosecution is now subject to the five-year statute of limitations. At the time that Mangahas is decided, United States v. Collins is before the Air Force Court of Criminal Appeals. That court applies Mangahas, and Collins’s prosecution is time-barred.

 

The Air Force Judge advocate general will certify the issue for appellate review. But while they’re awaiting the appeal to CAAF, CAAF confirms Mangahas in a case called United States v. Briggs and confirms the Air Force Court of Criminal Appeals in Collins, but subsequently, the Air Force Court of Criminal Appeals reverses the conviction of Humphrey Daniels because, again, the prosecution is time-barred, and the government appeals to the Supreme Court of the United States to basically answer the following question, which we addressed in the last podcast, which is whether the United States Court of Appeals for the Armed Forces erred in concluding, contrary to its own long-standing precedent, that the UCMJ, the Uniformed Code of Military Justice, allows prosecution of a rape that occurred between 1986 and 2006, only if it was discovered and charged within five years.

 

And so moving onto the release of the opinion, to sum up the arguments that were advanced and addressed by the Court—and there were some that weren’t, which Arthur will touch on later—but to sum up the arguments advanced and addressed by the Court, respondents contended that the phrase “punishable by death” in Article 43 means capable of punishment by death when all applicable law is taken into account, and including the Eighth Amendment, whereas the government sees the phrase “punishable by death” as meaning capable of punishment by death under the penalty provisions of the Uniform Code of Military Justice.

 

And so Justice Alito delivers the opinion of the unanimous Court in favor of the government and basically setting out three reasons for favoring the government’s interpretation. And he starts by noting that dictionary definitions of punishable lend some validity to the respondent’s arguments. But he goes on to say that definitions here aren’t going to answer the question, the question of punishable under what law, right? And so the Court then goes on to provide some context beyond those definitions, those dictionary definitions, and then goes on to say that these three reasons weigh heavily in favor of the government.

 

And so the first point that the Court lays out in its opinion is that a natural referent or a statute of limitations provision, within the Uniform code of Military Justice, is the Uniform Code of Military Justice itself. And so, as an example, the Court notes that no one would read Article 43’s reference to offenses to include those under state law. It’s a reference to offenses in the Uniform Code.

 

The Court also notes that many crimes include the “punishable by death” language in the Uniform Code, and Justice Alito says, “Presumably to save from including the long list of offenses punishable by death in Article 43.” Congress just said, “If it’s punishable by death in the punitive articles, there’s not going to be a time-bar. Everything else is five years.” And the Court specifically notes this is going to be true even if provisions elsewhere in the code might provide a defense against the imposition of the death penalty. So that’s the first prong of Justice Alito’s opinion, and I’ll hand it off to Arthur for that second prong.

 

Arthur Rizer:  Yeah. Thank you. Just tapping a little bit on what Richard said, one of the things that I thought was really interesting is they really drilled down on the word “uniform,” and that’s something that Richard pointed out, and it’s called the UCMJ for a reason. And they intended it specifically as an inclusive overhaul of how justice was to be administered in the Armed Forces. So it was interesting that they really focused on the word “uniform” to make their case and rightly so.

 

Another point that Alito wrote was specifically about the goals of the statute of limitations, and he wrote that one of the goals of the statute of limitations is clarity. In fact, it could be the paramount goal that all others are rest upon. And when Congress wrote the UCMJ, they would have undermined the goal of clarity by basing its application on future Supreme Court jurisprudence. And think about that, it’s an unusual stance from the Supreme Court to basically clip their own wings.

 

And I’ll say it again, when Congress wrote the UCMJ, they would’ve undermined the goal of clarity, as it relates to the statute of limitation, by basing its applicability on future Supreme Court jurisprudence, so therefore, it is unlikely that Congress would have forsaken the goal of clarity by intending it to be open for forces of extra UCMJ jurisprudence.

 

And the first two points almost wrap around on each other, exactly what Professor Sala was just talking about, when Article 43(a), which states there is no statute of limitations for these particular crimes, was written, the UCMJ is uniform, and it is unlikely that Congress would have forsaken its own goals as it relates to the statutes of limitations by leading extra UCMJ jurisprudence to be decided and formed later.

 

And if you watch—and I highly recommend that you do—the same presentation that Richard and I did a few months ago on the oral arguments, you can almost see that it’s coming. You can see the questions they were asking, just typically foreshadow what their decision was going to be.

Okay. Another point that I think is important is the underpinnings of the statute of limitations, and those of Cruel and Unusual Punishment Clause do not overlap, and that was another and probably the third point that Alito made:  when statutes of limitations concern the difficulty of putting together a case and presenting a prosecution, the Cruel and Unusual Punishment Clause concerns—really depending on who you ask, but this is what Alito, I believe, was saying—was either the evolving standard of decency or original intent.

 

And so if you run those kind of overarching ideals through this case, the Court basically says that—or Alito specifically says that—it is the government wins. The last thing that I’m going to talk about before turning it back over so we can talk about what Gorsuch added to this. But one of the arguments that the majority did not resolve—which I thought was particularly interesting because it almost seemed like they’re adding a hole to be addressed later on—but the CAAF previously held that Article 55, that’s the UCMJ’s own prohibition on Cruel and Unusual Punishment. And remember the UCMJ basically takes everything that we think about, and civilian life constitutional standards, and then codifies it.

 

So the Miranda Rights are codified within the UCMJ, and so, in essence, Brady is codified within the UCMJ. So Article 55 is the UCMJ’s prohibition of Cruel and Unusual Punishment, unless we afforded it as much protection as the Eighth Amendment. So that is a previous decision by CAAF, that’s U.S. v. -- is it Wappler? Is that the right, Richard? I think it is. It’s W-A-P-P-L-E-R. And the majority dismissed this by basically stating that direct permission of the death penalty for rape is to be the most natural place to look for Congress’s answer to whether or not rape was punishable by death, within the meaning of Article 43(a) in the first place. So, therefore, the Court says that they don’t need to decide whether or not Eighth Amendment applies through Article 55 of the UCMJ.

 

So there is some room for more things to be decided later on, but with an 8-0 decision, in essence, in favor of the government—well, dependent on how you count. 7-1 is where you want to put Gorsuch on that, which Professor Sala is going to talk about. And this was a really clear decision and really clear jurisprudence that I think will give clear guidance to the military. And that’s something else we talked about on the last Teleforum.

 

One of the themes that you’re going to see always, when it relates to UCMJ, is ensuring there’s bright-line rules. Because, ultimately, the military’s goal is not to decide what is right or wrong here in the comfort of U.S. courtrooms, but it’s to decide what is right or wrong during the horrors of war. And so we need to have very clear rules and guidance about what we’re telling our young men and women who put on the uniform. So I think what we’re going to talk about now is how Gorsuch added his fingerprints to this and then a few other notes that Professor Sala and I are going to add to the end.

 

Prof. Richard Sala:  Thanks a lot, Arthur. I appreciate it. So we’ll just take one brief moment to address the very, very short one-paragraph dissent laid out by Justice Gorsuch, who again, as Arthur noted, it is an 8-0 opinion because Justice Gorsuch agrees with the Court’s decision on the merits and Justice Barrett doesn’t participate in the opinion. But Justice Gorsuch does give us one paragraph essentially saying that he continues to believe that the Court lacks jurisdiction to hear appeals directly from the Court of Appeals for the Armed Forces.

 

And this is at least a little bit interesting because, while Justice Alito writes the opinion in this case, he also wrote the dissent in a case in 2018, Ortiz v. the United States, where Justice Alito, in that dissent, basically says these are Executive Branch officers. They are not yielding Article III power, and so they can’t exercise the federal government’s judicial power, and that fact basically would compel the Court to dismiss, in that case, Ortiz’s petition for lack of jurisdiction. And Justice Gorsuch just gives us a paragraph to reiterate the dissent in Ortiz, which Justice Gorsuch also joined, saying there’s an issue with jurisdiction here, but at least, six other members of the Court here believe there is jurisdiction. And, again, Justice Gorsuch joins the opinion, the Court’s decision, on the merits. So with that, I’ll turn it back over to Arthur.

 

Arthur Rizer:  Yeah. So just some closing thoughts and comments. If you guys listened to the last Teleforum, we were right. I am vindicated. We both predicted a decision in favor of the government. I predicted a 6-2 in favor, based on specifically on statutory grounds. And I think that prediction pretty much came to fruition with the Court only addressing this on statutory grounds and punting on the Eighth Amendment problem, which is I think exactly what we predicted. The main difference is that the 6-2 prediction turned into an 8-0.

 

And so I think some of my closing thoughts on this are, I think, this decision really leaves credence to the quote from Justice Kagan, some years ago, that we are all textuous now. And I see this as not only something a theme that we’re going to see -- obviously, we just saw in this case. I think it’s something you’re going to see in the Supreme Court for years to come; less decisions based on emotion, and what’s happening right now, and more based on what is the text.

 

I would be surprised if we saw the Court address whether or not the Eighth Amendment applies directly to the UCMJ in the next few years, when they can always cite big decisions on statutory grounds, but if this, or some other case like it, works its way up to the Court again, they don’t have much room to run away from that issue. So I predict that if they don’t want to address that, they’re just not going to pick it up. And that is my prediction over the next five or six years. Richard, do you have any imparting thoughts for our listeners who have so graciously given us their time?

 

Arthur Rizer:  Very briefly, I’ll just say I was also glad to see that we got it right. It came out in favor of the government; although, I will admit that I did think there was a chance that we would see more discussion of the Eighth Amendment issue, if not in the opinion, in the concurrence, but we didn’t see that. Nevertheless, an interesting case, and like Arthur, I think the opportunities to address the Eighth Amendment issue in the military context are going to be few and far between, so I would expect this to carry us along for quite some time.

 

Prof. Richard Sala:  Yeah. So we are willing and ready for questions. We went through that quicker than we expected, and we’re happy to talk about anything that you all want to discuss.

 

Nick Marr:  Great. Let’s open up the floor to audience questions. So we have two questions in the queue right now, but we’ll go to our first question now.

 

 Herb Ford:  Hey, thanks so much for the overview of the case. This is Herb Ford. I’m the general counsel for Concerned Vets for America and a former JAG. Not many military cases get to Supreme Court, so it’s great to see you guys analyze this one. So my main question, I guess, is this:  do you see this as essentially a clear textual application, that is do you see the justices simply reading the text that Congress has enacted in UCMJ in Article 34, as opposed to a legal analysis? Is this clearly a textual analysis of these facts and circumstances? And I’ll hold for you response. Thanks.

 

Arthur Rizer:  Yeah. That’s the way that I read it. And if you look at the -- I think the reason that I say that is if you look at-- and this is what Richard went over. If you look Alito’s first point -- and he specifically talks about Article 43, which states there is no statute of limitations for crimes punishable by death. And when they interpreted that, it should be done so with the UCMJ and not by looking at other external text, such as the Eighth Amendment per se, which might say punishment by death for rape cases is unconstitutional.

 

And the word that they latched on, and which is very simple and easy for them, is the word “uniform,” and it was intended as an inclusive overhaul on how all justice was to be administered in the United States. And you don’t need to look any further. It’s all right there on the text, and you don’t need to look at anything else. So that’s the way that I saw it. I don’t know if Richard has a different opinion or not.

 

Prof. Richard Sala:  I don’t think it’s a lot of difference. I did see it as a little bit more than strictly textual just because, again, Justice Alito starts out in the opinion looking to Webster’s Third New International Dictionary, and so on and so forth. And what a lot of those definitions turned on was—I’ll just give you an example, right? —deserving of or liable to punishment, capable of being punished by law or right, right? So I think if we applied that strictly without context, maybe, the respondent’s argument gained a little more traction.

 

So I certainly think it’s textual in that it’s based on the reading of the Uniform Code—maybe not turning on that specific word but understanding in context that when the statute refers to this chapter, and so on and so forth, that really having to put all the pieces of the code together and not focus on just one or two articles.

 

Arthur Rizer:  Yeah. I think another reason that I feel that way, and this could be just my own biases playing out, is if you look at -- I’m pretty sure I read every Supreme Court case that has come out since I have been an attorney. So the last 20 years, I think I’ve read every Supreme Court case at some point. And if you look at cases that are, what I would call, a textual case, they’re like this:  they’re short. They don’t have to get really deep into the facts. They don’t do really deep historical analysis of legal ideas. They’re in; they’re out. They’re to the point. I think that we saw -- where I teach as a professor, George Mason, named after Scalia, he was an expert at that type of legal decisions.

 

Maybe because it’s so short, that’s the overarching impression that I got. But I think Richard has made a really good point. They did do some almost worded out, in so many ways, to almost short circuit the argument from the other side, and I think that is obviously there. So, yeah, I definitely agree that there is some of that, as Richard pointed out, but I still see this as a pure textualist purist—how about that? —textualist decision.

 

Prof. Richard Sala:  Yeah. Thanks. And just a follow-up to that.

 

Arthur Rizer:  Yeah.

 

Prof. Richard Sala:  Yeah. So Congress actually amended that article, right? And so since the early 2000s -- so these are cases that precede that amendment, right?

 

Arthur Rizer:  That’s correct. The statute of limitations has been amended, so we wouldn’t see this in this way again. The period of article, the 120 article, there is no question as to whether it’s time-barred. It’s not time-barred.

 

Herb Ford:  Thanks.

 

Arthur Rizer:  Yeah. Hey, I’m a big fan of your organization, by the way. Thanks for listening. I appreciate it.

 

Herb Ford:  Sure thing.

 

Nick Marr:  Great. We’ll go to our next question now.

 

David Burge:  Yes, this is David Burge in Atlanta, Georgia. I’m a wholly civilian lawyer, so this is new area for me. I know the Court ducked the constitutional issues, but in the previous cases that you have read, are military defendants treated the same on constitutional issues or do they tend to get a -- I know the Constitution is the same for all citizens, but is the approach somewhat different in the Court’s treatment of these cases?

 

Arthur Rizer:  That’s a great question.

 

Prof. Richard Sala:  Yeah. Do you want to go first, Arthur?

 

Arthur Rizer:  Richard was a JAG. So I’m going to let him go over that. The only thing I would say is there’s been literature written about this, that in fact the military has been ahead in every single category of constitutional protections. The military offered those protections first. In Miranda Rights, long before the Miranda decision came out, the UCMJ and the military was offering the same types of protection, so it is really is ahead of the curve.

 

And I don’t think you can point to a single thing that we would look at today as a benchmark constitutional protection in the criminal case that the military didn’t do first, which is surprising. That actually surprises a lot of people, but I think I can prove it if you gave me examples, and I have enough time to do research. But Richard was a JAG officer and retired as a JAG officer, so he’s going to have a better insider -- in the inside [inaudible 24:22] on that, so I’ll turn it over to him.

 

Prof. Richard Sala:  So I’ll just be brief because I think trying to catalogue them all would take a long time. But there are some differences with the UCMJ approach and the constitutional issues that arise. I’ll just give you one example. Recently, you had the case, the Supreme Court decide Ramos v. Louisiana, which concluded that there was the unanimous jury requirement for convictions.

 

The military did not have a unanimous jury requirement, so the Uniform Code, I believe, when I was practicing it was two-thirds. I think it’s been changed to three-fourths now, but that’s just, at least, one example of a protection that’s a little bit different for people subject to the Uniform Code as opposed to their civilian counterparts. Hopefully, that, at least, touches or answers your question a little bit.

 

Arthur Rizer:  Yeah. And the one thing to keep in mind, if you read -- you have to read the UCMJ through the lens of war fighting. Everything in the UCMJ is supposed to support the idea that the military is different, and there needs to be a different set of rules. But there is this constant drum beat that despite that, we’re a great nation, and we’re a great nation because we provide constitutional protections, even when it’s hard. And there’s nothing harder than doing that in the field of combat.

 

I’m not a JAG, but I am a combat veteran, served in Iraq, the tail end of Battle of Fallujah, and I personally witnessed a constant professionalism from the criminal justice professionals in theater and the soldiers and marines that I dealt with. Rights were the utmost concern. That’s a great question. I thank you for calling in and listening.

 

Prof. Richard Sala:  Yeah. I think I just want to add one brief thing to that, Arthur, which is there is a, at least, I think there’s a legitimate question about how the Eighth Amendment would apply to service members, and like Arthur just alluded to, there’s plenty of literature out there talking about the military being a unique society. It’s one of the reasons we don’t enjoy the exact same First Amendment rights that our civilian counterparts do, right? There’s questions about knowing if it’s military necessity, about good order and discipline.

And so if you think about, for instance, Coker v. Georgia, which says that the death penalty can’t be applied to an individual convicted of rape of adult women, then we think about, well, if the military is a different society or different -- would they have the same [inaudible 27:05] sense of decency? For example—and I believe Justice Alito, and you can correct me if I’m wrong, Arthur, but I think Justice Alito alludes to this during an oral argument when he says—what if someone essentially went on a rape spree in the combat zone, but didn’t kill someone, would they be subject to the death penalty or would Coker v. Georgia apply? So I think those are the kinds of things we would be wrestling with if we had reached the Eighth Amendment issue, which we didn’t here.

 

David Burge:  I would assume another -- I assume desertion is probably still a death penalty offense, and that would be an interesting question should that come up again. That’s not murder.

 

Prof. Richard Sala:  Yeah. The Court actually lays out several in the opinion:  mutiny and sedition; misbehavior before the enemy; subordinate compelling surrender; aiding the enemy. There are several, so definitely Eighth Amendment issues to be considered there.

 

David Burge:  Thank you.

 

Prof. Richard Sala:  Yes, sir.

 

Nick Marr:  So we don’t have any callers in the queue right now. If you’d like to ask a question --

Arthur Rizer:  -- I’ll ask a question.

 

Prof. Richard Sala:  Go for it, Arthur.

 

Arthur Rizer:  Yeah. Richard, was there anything here that surprised you from being a former prosecutor in the Marine Corps—was there anything in either of the oral arguments, the briefs, that I know you and I both read or here that surprised you and made you feel that there was a knowledge gap between the people who make decisions and make law and those who actually have to be out in the field, and do all the soldiering, and do all the marine-ing? And I’m more curious about your personal feeling towards it.

 

Prof. Richard Sala:  That’s a great question, and now I have to spend a second thinking about it. I wouldn’t say I was that surprised overall. I think the one that I spent the most time thinking about was, I believe, from the respondent’s brief where essentially it appears to me that they tried to treat different kinds of rape differently under Coker v. Georgia, right? So there are some where if there’s a rape that happened in the continental United States on the base, that might be treated one way, but if there’s one that happened in the combat zone, it might be charged as a war crime.

 

So that one, I spent the most time wrestling with because at least as I was thinking about it, I was thinking you’d want a unified approach to this kind of thing, or we end up again with the question of whether or not the Eighth Amendment applies the same way to the military as it does to its civilian counterpart. So that was the one I wrestled with the most.

 

But I think the outcome here is pretty straightforward, based on a lot of considerations that I think prosecutors would appreciate just about when the statute of limitations is going to be, how long do we have to work with the victim, how long do we have to try to gather evidence, and the investigating that goes on, what do we do when someone comes to us years later to make a report, and so not just for -- by the way, not just for prosecutors and lawyers but for commanders, right, for those convening authorities who have to make these tough kinds of decisions without the benefit really of a Juris Doctor. So, yeah, hopefully, somewhere in there, Arthur, I answered your question.

 

Arthur Rizer:  Yeah. And, I guess, one more I had for you was, when you read Gorsuch’s opinion -- I haven’t heard of this idea that CAAF doesn’t fall into the jurisdiction of the Supreme Court. I’ve never even knew there was an argument out there. I guess I see that he cited the Ortiz case, but is that something that you’ve heard about that there is this series from jurists, that CAAF, the Court of Armed Forces, doesn’t even fall under the jurisdiction of the Supreme Court?

 

Prof. Richard Sala:  I’m sorry. I actually remember when Ortiz came out, and that was one of the first times I heard it, but I also want to say that if you go back into the various filings, and pleadings, and so on and so forth, with the Supreme Court, that the respondents actually raised this early on, and it did not gain any traction.

 

Arthur Rizer:  Yeah. I actually blew it off. I now think about it. When I saw that, I was like, “Okay, they’re just throwing darts at a wall blindfolded.” To see Gorsuch write it out like that, I was like, “Oh, there are some serious thinkers that actually believe this.” That was really interesting. Yeah. That’s great.

 

Prof. Richard Sala:  They’re Article II courts.

 

Arthur Rizer:  Yeah. Yeah. Yeah, yeah. Cool. Nick, do we have anybody else?

 

Nick Marr:  No one in the queue right now, so I’ll give a chance for closing remarks. If we get a question, I’ll let you know, but, otherwise, we’ll wrap up a bit early this afternoon.

 

Arthur Rizer:  Yeah. I already gave my closing remarks. I’m good.

 

Nick Marr:  You don’t have. Just if you want to.

 

Prof. Richard Sala:  I guess I could just close up by saying I was glad to fall in on a Teleforum with only a 12-page opinion, and I hope to see more of them in the future.

 

Nick Marr:  There you go. Well, thank you for all for joining us today, and on behalf of The Federalist Society, I want to thank you, Arthur and Richard, our experts, for the benefit of your valuable time and expertise this afternoon, to our audience for calling in, and thanks for your great questions.

 

And as always, we welcome your feedback by email at [email protected], and be keeping an eye on your emails and our website for announcements about upcoming Teleforum calls and virtual events, and join us tomorrow at noon eastern time for a virtual panel on court reform proposals and discussions. So register for that on our website. Thank you all for joining us this afternoon. We are adjourned.

 

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Dean Reuter:  Thank you for listening to this episode of Teleforum, a podcast of The Federalist Society’s practice groups. For more information about The Federalist Society, the practice groups, and to become a Federalist Society member, please visit our website at fedsoc.org.