United States v. Adams
2015 CAAF LEXIS 344
| C.A.A.F. | 2015Background
- Specialist Matthew R. Adams Jr. was charged with robbery and other offenses; he pleaded and was convicted of larceny (a lesser-included offense) after a military judge admitted portions of his sworn confession.
- CID searched Adams’ home based on a tip from co-defendant DT and found a Smith & Wesson .40 Sigma handgun; no cocaine was recovered.
- Adams’ confession described meeting a drug dealer named “Ootz” at a Walmart, moving to a nearby Microtel, Adams brandishing a .40 S&W while DT grabbed cocaine, and returning to post.
- The government did not call Ootz or the alleged accomplices at trial; it sought to admit the confession with corroboration from CID agents’ testimony and the recovered handgun.
- The military judge excised some portions for lack of corroboration but admitted parts identifying the Walmart/Microtel, the victim name, and the gun; the Army CCA affirmed.
- This Court reviewed whether the admitted portions of the confession were properly corroborated under M.R.E. 304(c) and reversed, finding insufficient corroboration of multiple essential facts and that admission was prejudicial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the portions of Adams’ confession were properly corroborated under M.R.E. 304(c) | Prosecution: the handgun found, testimony about a known dealer named Ootz, and testimony about a Walmart/Microtel sufficiently corroborate essential facts of the confession. | Adams: key essential facts (the theft, accomplices’ actions, time, motive, and that DT grabbed cocaine) lacked independent corroboration and therefore must be excised. | Court: The military judge abused discretion admitting numerous uncorroborated essential facts; only the handgun possession was adequately corroborated; reversal and set-aside of findings and sentence. |
Key Cases Cited
- Opper v. United States, 348 U.S. 84 (Supreme Court) (establishes need for independent corroboration to justify inference of truth of confession)
- Smith v. United States, 348 U.S. 147 (Supreme Court) (discusses purpose of corroboration to guard against false confessions)
- United States v. Cottrill, 45 M.J. 485 (C.A.A.F. 1997) (corroboration must raise inference of truth as to essential facts; need not prove all elements)
- United States v. McCollum, 58 M.J. 323 (C.A.A.F. 2003) (standard of review: military judge’s admission of evidence reviewed for abuse of discretion)
- United States v. Grant, 56 M.J. 410 (C.A.A.F. 2002) (corroboration must be independent; slight corroboration can suffice but must meet rule)
- United States v. McClain, 71 M.J. 80 (C.A.A.F. 2012) (discusses required quantity and quality of corroborating evidence)
- United States v. Rounds, 30 M.J. 76 (C.M.A. 1990) (identifies categories of essential facts relevant to corroboration)
- United States v. Seay, 60 M.J. 73 (C.A.A.F. 2004) (example of broader inference use in corroboration analysis; discussed and limited by majority)