The Court of Appeals for the Armed Forces (CAAF) has reversed the ruling of the Navy-Marine Corps Court of Criminal Appeals (CCA) that originally upheld a conviction in United States v. Darnall. The CAAF found no substantial evidence for Darnall to have ever been detained and questioned by investigators, which poses a direct violation of the defendant’s Fourth Amendment rights. It further concluded that the violation of Darnall’s Constitutional rights should have led to the suppression of all evidence gathered within the subsequent defendant interrogation. With all matters considered, the CAAF has unanimously reversed the conviction.
DETAILS OF U.S. V. DARNALL
Hospitalman Darnall was detained based on accusations of trafficking, manufacturing, and distributing illicit controlled substances, such as steroids and customized drugs. He pleaded not guilty and maintained innocence during the trial procedures. The court would subsequently find him guilty and enact harsh penalizations, including rank reduction, six years of confinement, financial forfeitures, and a dishonorable discharge from service.
The allegations against Darnall first began after military criminal investigators intercepted a package that contained a chemical compound commonly used in the manufacturing of several designer drugs. The parcel was reportedly addressed to Darnall and originating off-base. Investigators decided that the substances in the package must be used for drug crimes, swapped out the parcel for an empty one, and apprehended Darnall when he arrived to claim it. After he was handcuffed, an interrogation promptly began, during which he revealed potentially incriminating circumstances and evidence.
Immediately noticing the questionable reasoning behind his apprehension, Darnall and his defense moved to suppress the evidence gained through interrogation within the first trial. The suppression motion was denied by the military judge, whose decision would later be reaffirmed by the CCA. It is worth noting that the CCA did find that there was no strong evidence to conclude that Darnall did indeed live at the address written on the parcel in question.
CAAF REASON FOR REVERSING THE CONVICTION
When the appellate case of U.S. v. Darnall reached the CAAF, it reversed the conviction and decidedly so. It held that the military criminal investigators never had clear reasoning for apprehending Darnall or switching out his parcel. The statement of the CAAF was notably pointed, claiming that the investigation conducted was “sloppy and apathetic […]” and could be easily seen as a Fourth Amendment violation.
Within its explanation for the reversal of two lower courts’ decisions, the CAAF cited both Rule for Courts-Martial 302(c) and U.S. v. Leedy. The statutes and case laws mandate that apprehension is only permissible when paired with probable cause, and that probable cause cannot be based on “bare suspicion,” respectively. It concluded that neither one of the established standards was met.
The CAAF also found questionability within the investigators’ decision to reroute the fake parcel to the regimental mailroom. If it had been permitted to go to its original destination, the apprehension of whomever claimed it would have made more sense, rather than forcing Darnall to be the one to collect it. Judge Sparks of the CAAF went on to explain how the investigators could have conducted the investigation and interrogation in a way that did not violate the Fourth Amendment and that could have possibly kept the evidence as admissible. In recognition that alternative methods existed but were not used, it can be concluded further that despite the good faith of the investigations, the professional blunders were avoidable and ultimately damaging to the case against Darnall.
Military Criminal Defense Attorney Joseph Jordan is well-versed in the Uniform Code of Military Justice (UCMJ) and how it pertains to both court-martial, military trials, and appeals to CCA and CAAF. Service members in all branches of the Armed Forces can rely on his firm for unwavering, tenacious, and intelligent defense from a civilian lawyer trusted in military bases and headquarters across the globe. Call (866) 361-4723 or use an online contact form if you require his assistance and representation for a military criminal defense case of your own.