United States v. REDMOND
202300130
| N.M.C.C.A. | Jun 11, 2025Background
- Petty Officer Roneshia L. Redmond was convicted at a special court-martial, contrary to her pleas, of willful disobedience of a petty officer under Article 91 of the UCMJ.
- The underlying conduct involved Redmond willfully disobeying a lawful order not to drive away from a security checkpoint at Naval Support Activity Souda Bay, Greece, on 10 December 2022.
- A specification for disobeying an order to submit to a breath analysis was dismissed without prejudice; she was found not guilty on a separate charge and specification under Article 92 (failure to obey a lawful order).
- Redmond appealed, arguing factual insufficiency of the evidence supporting her conviction.
- The appellate court initially affirmed, but the Court of Appeals for the Armed Forces set that aside, directing a new factual sufficiency review per United States v. Harvey.
- On remand, the Navy-Marine Corps Court of Criminal Appeals again affirmed the conviction and sentence, but directed corrections to the Entry of Judgment for completeness and accuracy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Factual sufficiency of conviction for willful disobedience under Article 91 | Redmond argued evidence insufficient to support her conviction. | Government contended evidence showed clear willful disobedience of a lawful order. | Court found evidence sufficient and affirmed conviction. |
| Procedural sufficiency of Entry of Judgment | Redmond entitled to accurate court records. | Government did not argue prejudice. | Court modified the Entry of Judgment to correct deficiencies. |
Key Cases Cited
- United States v. Harvey, 85 M.J. 127 (C.A.A.F. 2024) (clarifies standard for factual sufficiency review in military criminal convictions)
- United States v. Wadaa, 84 M.J. 652 (N-M. Ct. Crim. App. 2024) (addresses requirements for a proper summary of referred charges in Entry of Judgment)
- United States v. Sutton, 81 M.J. 677 (N-M. Ct. Crim. App. 2021) (the accused is entitled to court-martial records accurately reflecting proceedings)
- United States v. Crumpley, 49 M.J. 538 (N-M. Ct. Crim. App. 1998) (emphasizes importance of accurate appellate records in military justice)