United States v. Specialist ANTIONE D. WILLIAMS, ARMY 20130446

Appellant, a Fort Hood military police officer, contacted women advertising prostitution while on patrol and lured them onto post by claiming to run a prostitution sting; he never intended to pay and instead threatened arrest to coerce sexual acts.
Four separate incidents involving four women: one early attempt was aborted; in two incidents appellant coerced oral sex after pretending to be conducting a sting; in a fourth (RL) he drew a loaded firearm, forced the woman from her car, removed her shorts, and penetrated her.
Appellant pleaded guilty to several offenses (including attempted sexual assault, attempting to patronize a prostitute, sodomy, abusive sexual contact, and patronizing a prostitute) and pleaded not guilty to others (including rape by displaying a firearm).
The military judge convicted appellant (some contrary to pleas) of multiple sexual and non-sexual offenses; original sentence was dishonorable discharge, 50 years confinement (later reduced to 45), then approved by convening authority per PTA to 15 years confinement.
On appeal the Army Court reviewed plea acceptances, alleged multiplicious/unreasonable multiplication of charges, and dilatory post-trial processing; it conditionally dismissed several specifications and reassessed the sentence, ultimately affirming the remaining findings and the PTA-approved sentence.

Issue	Appellant's Argument	Government's Argument	Held
Whether appellant can be convicted of both patronizing a prostitute and rape for the same act (RL)	Patronizing plea and not-guilty plea to rape are inconsistent; cannot be guilty of both when rape was by force not inducement	The government proved rape by force; patronizing was predicated on inducement theory	Court: convictions inconsistent; patronizing spec (Art. 134) conditionally dismissed
Whether sodomy and abusive sexual contact charges for the same victim are unreasonably multiplied	Pleaded guilty to sodomy and abusive sexual contact arising from same conduct	Prosecution treated separate statutory offenses as distinct	Court: sodomy specifications conditionally dismissed as unreasonable multiplications with abusive sexual contact specs
Whether attempted patronizing and attempted sexual assault for the same victim (NF) are unreasonably multiplied	Guilty pleas to both arose from one transaction; duplicative charging	Prosecution maintained distinct attempt theories	Court: attempted patronizing spec conditionally dismissed as unreasonable multiplication
Whether post-trial processing delay required relief	Appellant asserted delay without detailed analysis	Government: no due-process violation; processing within acceptable bounds	Court: no Moreno due-process violation; denied additional relief

Jackson v. Virginia, 443 U.S. 307 (legal sufficiency standard) (establishing standard for reviewing sufficiency of evidence)
Ball v. United States, 470 U.S. 856 (unapproved convictions have collateral consequences and constitute unauthorized punishment)
United States v. Campbell, 71 M.J. 19 (C.A.A.F.) (prohibition on unreasonable multiplication of charges addresses prosecutorial overreach)
United States v. Moreno, 63 M.J. 129 (C.A.A.F.) (post-trial delay due-process framework)
United States v. Winckelmann, 73 M.J. 11 (C.A.A.F.) (standards for reassessing sentence on appeal)
United States v. Briton, 47 M.J. 195 (C.A.A.F.) (conditioning dismissal when gravamen offenses survive final judgment)