United States v. Briggs

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United States v. Briggs | |
Term: 2020-2021 (Originally 2019-2020) | |
Important Dates | |
Argument: October 13, 2020 (Postponed from March 23, 2020)<be>Decided December 10, 2020 | |
Outcome | |
Reversed and remanded | |
Vote | |
8-0 | |
Majority | |
Chief Justice John G. Roberts • Clarence Thomas • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh | |
Concurring | |
Neil Gorsuch |
United States v. Briggs is a case argued before the Supreme Court of the United States on October 13, 2020, during the court's October 2020-2021 term. The case came on a writ of certiorari to the United States Court of Appeals for the Armed Forces. It was consolidated with United States v. Collins.[1][2]
In a unanimous ruling, the court reversed the Court of Appeals for the Armed Forces' ruling and remanded the case for further proceedings, holding that the respondents' prosecutions for rape were timely under the Uniform Code of Military Justice.[3] Justice Samuel Alito delivered the opinion of the court. Justice Neil Gorsuch filed a concurring opinion. Justice Amy Coney Barrett took no part in the consideration or decision of the case. Click here for more information about the ruling.
Oral argument for United States v. Briggs was initially scheduled for March 23, 2020, during the court's October 2019-2020 term. However, the U.S. Supreme Court announced on March 16 that it was postponing the 11 oral arguments originally scheduled during its March sitting. In a press release, the court said the delay was "in keeping with public health precautions recommended in response to COVID-19."[4] COVID-19 was the abbreviation for coronavirus disease 2019, caused by SARS-CoV-2.
- Click here for more information about the court's response to the coronavirus pandemic.
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You can review the lower court's opinion here for United States v. Briggs and here for United States v. Collins.[6][7]
Timeline
The following timeline details key events in United States v. Briggs:
- December 10, 2020: The U.S. Supreme Court reversed the Court of Appeals for the Armed Forces' decision and remanded the case.
- October 13, 2020: Oral argument was heard.
- March 16, 2020: The U.S. Supreme Court postponed its March sitting. Oral arguments in United States v. Briggs were initially scheduled for March 23, 2020.
- November 15, 2019: The U.S. Supreme Court agreed to hear the case.
- July 22, 2019: The United States of America filed a petition with the U.S. Supreme Court.
- February 22, 2019: The United States Court of Appeals for the Armed Forces reversed the Air Force Criminal Court of Appeals' decision and dismissed the charge.
The following timeline details key events in United States v. Collins:
- November 15, 2019: The U.S. Supreme Court agreed to hear the case.
- August 9, 2019: The United States of America filed a petition with the U.S. Supreme Court.
- May 12, 2019: The Court of Appeals for the Armed Forces dismissed the charge and vacated the sentence.
Background
On November 15, 2019, the U.S. Supreme Court agreed to hear United States v. Briggs and United States v. Collins as consolidated cases.[8]
In 2014, a general court-martial convicted Michael Briggs of one charge of rape in violation of Article 120(a), Uniform Code of Military Justice (UCMJ), 10 U.S.C. § 920 for an event that occurred in 2005.[9] Briggs appealed to the United States Air Force Court of Criminal Appeals, seeking to file a supplemental assignment of error asserting that the statute of limitations had expired, along with unrelated assignments of error. The Air Force Criminal Court of Appeals denied leave to file on the basis that Briggs had not raised the statute of limitations during the trial, rejected the other assignments of error, and affirmed the trial court findings and sentence.[6]
Briggs filed a petition for grant of review with the Court of Appeals for the Armed Forces. The court granted review of one assignment of error filing concerning the lower court's judicial composition, denied review of an assignment of error filing stating that Briggs' counsel failed to raise the statute of limitations, and affirmed the decision of the Air Force Criminal Court of Appeals. Briggs appealed to the Supreme Court of the United States on a writ of certiorari regarding the judicial composition issue. The Supreme Court initially denied the petition. Upon reconsideration, the Supreme Court granted the petition, vacated the Court of Appeals for the Armed Forces' judgment affirming the Air Force Criminal Court of Appeals' decision, and remanded the case to the Court of Appeals for the Armed Forces for further consideration. On remand, the Court of Appeals for the Armed Forces reversed the decision, dismissed the charge, and vacated the sentence. The United States of America appealed the decision to the Supreme Court on a writ of certiorari.[6]
Similarly, in United States v. Collins, Richard Collins was found guilty of rape in violation of Article 120(a), Uniform Code of Military Justice (UCMJ), 10 U.S.C. § 920. On appeal, Collins asserted that the statute of limitations had expired, and the Court of Appeals for the Armed Forces dismissed the charge and vacated the sentence.[7]
Legal definitions
Uniform Code of Military Justice (UCMJ)
Article 120(a) of the Uniform Code of Military Justice (UCMJ), 10 U.S.C. § 920 reads as follows:[9][7]
“ | Rape and sexual assault generally
(a) Rape.-Any person subject to this chapter who commits a sexual act upon another person by-
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” |
Questions presented
The petitioner presented the following questions to the court:[5]
Questions presented:
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Outcome
In a unanimous ruling, the court reversed the Court of Appeals for the Armed Forces' ruling and remanded the case for further proceedings, holding that the respondents' prosecutions for rape were timely under the Uniform Code of Military Justice.[3] Justice Samuel Alito delivered the opinion of the court. Justice Neil Gorsuch filed a concurring opinion. Justice Amy Coney Barrett took no part in the consideration or decision of the case.
Opinion
In his opinion, Justice Samuel Alito wrote:[3]
“ | We must decide in these cases whether, under the Uniform Code of Military Justice (UCMJ), a prosecution for a rape committed during the period from 1986 to 2006 had to be commenced within five years of the commission of the charged offense or whether such a prosecution could be brought at any time, as is the rule at present. The Court of Appeals for the Armed Forces (CAAF), reversing its prior decisions on this question, held that the statute of limitations was five years and that it therefore barred the rape convictions of respondents, three military service members. See 78 M. J. 289 (2019); 78 M. J. 415 (2019); 79 M. J. 199 (2019). We granted certiorari, 589 U. S. ___ (2019), and now reverse.
... On balance, we find the Government's interpretation more persuasive. The meaning of a statement often turns on the context in which it is made, and that is no less true of statutory language. See Tyler v. Cain, 533 U. S. 656, 662 (2001); Deal v. United States, 508 U.S. 129, 132 (1993); A. Scalia & B. Garner, Reading Law 167 (2012). And in these cases, context is determinative. The phrase “punishable by death” appears in a statute of limitations provision for prosecutions under the UCMJ, and for at least three reasons, that context weighs heavily in favor of the Government's interpretation. ... Viewing Article 43(a) in context, we are convinced that "punishable by death" is a term of art that is defined by the provisions of the UCMJ specifying the punishments for the offenses it outlaws. And under this interpretation, respondents' prosecutions were timely. The judgments of the CAAF are reversed, and the cases are remanded for further proceedings consistent with this opinion.[10] |
” |
—Justice Samuel Alito |
Concurring opinion
Justice Neil Gorsuch filed a concurring opinion. In his concurring opinion, Justice Gorsuch wrote:[3]
“ | I continue to think this Court lacks jurisdiction to hear appeals directly from the CAAF. See Ortiz v. United States, 585 U.S. ___, ___ (2018) (ALITO, J., dissenting). But a majority of the Court believes we have jurisdiction, and I agree with the Court’s decision on the merits. I therefore join the Court's opinion.[10] | ” |
—Justice Neil Gorsuch |
Text of the opinion
Read the full opinion here.
Oral argument
Audio
Audio of oral argument:[11]
Transcript
See also
External links
- Search Google News for this topic
- U.S. Supreme Court docket file - United States v. Briggs (petitions, motions, briefs, opinions, and attorneys)
- SCOTUSblog case file for United States v. Briggs
- U.S. Supreme Court docket file - United States v. Collins (petitions, motions, briefs, opinions, and attorneys)
- SCOTUSblog case file for United States v. Collins
Footnotes
- ↑ United States v. Collins also came on a writ of certiorari to the United States Court of Appeals for the Armed Forces. The docket number is 19-184.
- ↑ SCOTUSblog, "United States v. Briggs," accessed November 18, 2019
- ↑ 3.0 3.1 3.2 3.3 Supreme Court of the United States, "United States v. Briggs: Opinion of the Court," decided December 10, 2020
- ↑ U.S. Supreme Court, "Press release from March 16, 2020," accessed March 16, 2020
- ↑ 5.0 5.1 Supreme Court of the United States "United States v. Briggs: Questions presented," accessed November 18, 2019
- ↑ 6.0 6.1 6.2 United States Court of Appeals for the Armed Forces, "United States v. Briggs," accessed November 18, 2019
- ↑ 7.0 7.1 7.2 United States Court of Appeals for the Armed Forces, "United States v. Collins," accessed November 18, 2019
- ↑ Supreme Court of the United States, "Order List," November 15, 2019
- ↑ 9.0 9.1 9.2 United States Code, "10 USC 920: Art. 120. Rape and sexual assault generally," accessed January 2, 2020
- ↑ 10.0 10.1 10.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed October 19, 2020