In re Daniels v. United States
Misc. Dkt. No. 2025-06
| A.F.C.C.A. | Jul 25, 2025Background
- Lieutenant Colonel Daniels III was convicted at a general court-martial of negligent dereliction of duty, rape, and conduct unbecoming an officer, all under the Uniform Code of Military Justice.
- Daniels’ case has been subject to extensive appellate review, including remands and partial affirmances and reversals.
- On 25 February 2025, the Air Force Court of Criminal Appeals issued a new opinion after a remand from a higher court.
- On 6 June 2025, Daniels petitioned the United States Court of Appeals for the Armed Forces (CAAF), with that review pending.
- Daniels then filed a pro se extraordinary writ petition with the Air Force Court of Criminal Appeals, citing newly discovered evidence of fraud.
- The court treated the filing as a petition for a writ of error coram nobis but questioned its jurisdiction since CAAF review was pending.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Whether the court could grant coram nobis relief | Daniels argued newly discovered evidence warrants relief for a fundamentally flawed conviction. | Government (implicitly) argued jurisdiction lies with CAAF due to pending review. | Court lacked jurisdiction to consider the petition while CAAF review was pending. |
Key Cases Cited
- Loving v. United States, 62 M.J. 235 (C.A.A.F. 2005) (all writs authority does not expand jurisdiction of military courts)
- United States v. Denedo, 556 U.S. 904 (2009) (scope and requirements for writ of error coram nobis in military justice system)
- Clinton v. Goldsmith, 526 U.S. 529 (1999) (All Writs Act does not give appellate military courts jurisdiction beyond that granted by statute)