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United States v. Briggs

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Supreme Court of the United States
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.
  • Click here for more information about political responses to the pandemic.
HIGHLIGHTS
  • The case: Michael Briggs was found guilty of rape in 2014 in a general court-martial for an act that occurred in 2005. On appeal, Briggs asserted that the statute of limitations had expired. The United States Air Force Criminal Court of Appeals affirmed the court-martial's decision. On appeal, the Court of Appeals for the Armed Forces affirmed in part and denied review in part. On appeal, the Supreme Court granted a petition for a writ of certiorari, vacated the Court of Appeals for the Armed Forces' judgment, and remanded. The Court of Appeals for the Armed Forces reversed the Air Force Criminal Court of Appeals' decision and dismissed the charge against the respondent. The United States of America filed a petition for a writ of certiorari with the Supreme Court.
  • The issue: "Whether the Court of Appeals for the Armed Forces erred in concluding-contrary to its own longstanding precedent-that the Uniform 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."[5]
  • The outcome: In a unanimous ruling, the court reversed the judgment of the U.S. Court of Appeals for the Armed Forces and remanded the case for further proceedings, holding that the respondents' prosecutions for rape were timely under the Uniform Code of Military Justice.


    • 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-
    (1) using unlawful force against that other person;
    (2) using force causing or likely to cause death or grievous bodily harm to any person;
    (3) threatening or placing that other person in fear that any person will be subjected to death, grievous bodily harm, or kidnapping;
    (4) first rendering that other person unconscious; or
    (5) administering to that other person by force or threat of force, or without the knowledge or consent of that person, a drug, intoxicant, or other similar substance and thereby substantially impairing the ability of that other person to appraise or control conduct;[9][10]

    		”

    Questions presented

    The petitioner presented the following questions to the court:[5]

    Questions presented:
    • Whether the Court of Appeals for the Armed Forces erred in concluding-contrary to its own longstanding precedent-that the Uniform 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.

    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.


    The question before us is important, and there are reasonable arguments on both sides, but resolving the question does not require lengthy analysis. During the period at issue, Article 120(a) of the UCMJ provided that rape could be “punished by death,” 10 U. S. C. §920(a) (1982 ed.); §920(a) (1994 ed.), and Article 43(a), which was amended in 1986, provided that an offense "punishable by death" could be tried and punished "at any time without limitation," National Defense Authorization Act for Fiscal Year 1987, 100 Stat. 3908; see 10 U. S. C. §843(a) (1988 ed.). The crux of the question before us is the meaning of the phrase “punishable by death” in the latter provision. Respondents contend—and the CAAF held—that the phrase means capable of punishment by death when all applicable law is taken into account. See United States v. Mangahas, 77 M. J. 220, 224 (2018). Because this Court held in Coker v. Georgia, 433 U. S. 584, 592 (1977), that the Eighth Amendment forbids a death sentence for the rape of an adult woman, respondents argue that they could not, in fact, have been sentenced to death, and therefore the statute of limitations for their crimes (committed in 1998, 2000, and 2005) was the 5-year statute that generally governed non-capital offenses. See 10 U. S. C. §843(b)(1) (1994 ed.); §843(b)(1) (2000 ed.). By contrast, the Government argues that Article 43(a)’s reference to "punishable by death" means capable of punishment by death under the penalty provisions of the UCMJ, and since Article 120(a) provided (despite Coker) that rape could be punished by death, it follows that there was no time limit for filing rape charges against respondents.

    ... 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

    Footnotes

    1. ↑ 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.
    2. ↑ SCOTUSblog, "United States v. Briggs," accessed November 18, 2019
    3. ↑ 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
    4. ↑ U.S. Supreme Court, "Press release from March 16, 2020," accessed March 16, 2020
    5. ↑ 5.0 5.1 Supreme Court of the United States "United States v. Briggs: Questions presented," accessed November 18, 2019
    6. ↑ 6.0 6.1 6.2 United States Court of Appeals for the Armed Forces, "United States v. Briggs," accessed November 18, 2019
    7. ↑ 7.0 7.1 7.2 United States Court of Appeals for the Armed Forces, "United States v. Collins," accessed November 18, 2019
    8. ↑ Supreme Court of the United States, "Order List," November 15, 2019
    9. ↑ 9.0 9.1 9.2 United States Code, "10 USC 920: Art. 120. Rape and sexual assault generally," accessed January 2, 2020
    10. ↑ 10.0 10.1 10.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    11. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed October 19, 2020
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