Eye strain in Spain

A delegation of the Unified Association of Civil Guards (AUGC) in Avila, Spain, made public an important judgment issued by the local Military Tribunal, which sanctioned one of their affiliates with a light penalty after he had originally been given a more serious penalty for the "crime" of "clumsiness" for accidentally breaking the screen of the computer he was using, rendering it useless.

The colleague worked in the traffic department in Avila and on a daily basis risked his life, although assisting citizens on the highway is not considered a risky profession.   The Military Tribunal overturned the lower court's decision and nullified the penalty due to the lack of impartiality of the sanctioning body.   The AUGC, a union that defends the rights of the Civil Guards, had denounced for years that the Civil Guards opts for applying a disproportionate and excessive disciplinary regime which demonstrates its lack of leadership.  According to the union, given its incapacity to lead, the Civil Guard opts for a policy of punishment and fear.  The union's lawyer was able to achieve the reversal of the penalty in the Military Tribunal.

New court begins work in South Sudan

A general court-martial has commenced work in South Sudan. Excerpt from this account:

A Military General Court Martial was inaugurated on Tuesday in the Western Bahr el Ghazal State capital, Wau, to hear criminal cases involving soldiers.

Speaking during the ceremony, Gen. Sten Kamilo Mboro, President of the SSPDF [South Sudan People's Defence Forces] General Court Martial, who led a delegation from Juba, revealed that the High Command directed them to open the court in Wau and urged military judges to be impartial.

“Although we delayed due to logistical challenges, we have finally come as a team to establish a court of law for the defense forces of South Sudan in Wau,” he stated. “We came under Order Number 5/2024, and we are not here to discriminate or trample on anyone’s rights, but all people will be judged while their rights are upheld.”

For his part, Major General Jiel Mangok Yel, the Commander of the SSPDF’s Fifth Infantry Division based in Wau, said the court martial will work to ensure accountability and justice, especially in cases involving military personnel and civilians.

Posthumous promotion for Captain Dreyfus?

A bill to promote Captain Alfred Dreyfus (1859-1935) posthumously to brigadier general has passed the French National Assembly and is awaiting action by the Senate. Details here.

Juneteenth

Kampala notes

President Yoweri Museveni of Uganda has assented to recent legislation that nullifies important aspects of the landmark Kabaziguruka decision of the Supreme Court. We'll have more on this in due course.

Saint Paul University awards Honorary Doctorate to Colonel-Maitre Michel W. Drapeau - June 16, 2025

 Ottawa, Ontario, Canada. 

Saint Paul University has awarded an honorary doctorate degree to Colonel-Maitre Michel W. Drapeau, a lawyer and adjunct professor of law at the Faculty of Law, University of Ottawa.

The honorary doctorate is the highest distinction awarded by a university. It honors individuals whose outstanding achievements have made a significant contribution to society, the university, and their profession. Through this recognition, Saint Paul University wishes to highlight Colonel-Maitre Drapeau's remarkable commitment to justice, institutional integrity, and the common good.

Following a 34-year career in the Canadian Armed Forces, Mr. Drapeau dedicated himself to public service, academia, and legal practice. As the founder of a law firm specializing in military law, he has stood out for his leadership in defending the rights of Canadian Armed Forces members, veterans, and their families. He has also played a major role in public debates surrounding military justice and access to information, contribution significantly to national reforms. His outstanding work has been recognized on numerous occasions through various awards and medals, including the Military Merit Medal and the King Charles III Coronation Medal. 

"Colonel Drapeau embodies the values of justice, moral courage, and community services that we promote at Saint Paul University. Awarding him this honorary doctorate is a way to recognize an exceptional and meaningful journey that inspires our entire university community." said Rector Louis Patrick Leroux.

Missing in action?

The Supreme Court of Pakistan's website remains inaccessible, so far as Global Military Justice Reform can tell. Neither the majority nor dissenting opinions in the May 8, 2025 Military Courts Case decision are available to the public. If any reader has digital copies, please send them to the Editor or post links to them using the comments function.

Cameroon military justice

For a primer on military justice in Cameroon see Buma Tita Valentine & Nubed Fri Grace Godimer, Criminal Proceedings Before the Military Tribunal in Cameroon, 2 Am. J. Pol. Sci. & Leadership Stud. No. 6, 34 (June 2025).

Is the federal call-up of California National Guard troops lawful?

 The State thinks not, according to this letter.

Red, White, and Bluebook -- guest post by Dwight H. Sullivan

Five years after the 21st edition’s debut, the Bluebook’s publishers have issued a 22d edition. They inform us that this edition makes “hundreds of edits, large and small.” Preface, THE BLUEBOOK: A UNIFORM SYSTEM OF CITATION (22d ed. 2025). You can order your own hard copy here. Mine arrived within 52 hours of placing the order. When you order the book, you will also receive an access key that will allow you to use the Bluebook Online for 30 days.

The issuance of a new Bluebook edition is particularly important for military appellate litigators, given various military appellate courts’ requirement that counsel cite authorities in accordance with the Bluebook’s often-arcane edicts. For example, CAAF Rule 37(c)(2) provides, “Citations must conform with The Bluebook: A Uniform System of Citation.” There is more than a little irony in that requirement as CAAF does not cite its own decisions in the manner prescribed by the Bluebook. Like Table 1.1 of the 21st edition, that table in the 22d edition provides for CoMA citations, “Cite to C.M.A., if therein.” Yet CAAF’s style is to provide parallel citations to both C.M.A. and C.M.R. when one of its decisions was reported in both. E.g., United States v. Jacinto, __ M.J. __, No. 24-0144, slip op. at 3 n.2 (C.A.A.F. May 19, 2025) (citing “United States v. DuBay, 17 C.M.A. 147, 37 C.M.R. 411 (1967)”). Just as did the 21st edition, the 22d edition of the Bluebook misidentifies Lawyers Co-operative Publishing Company’s Court-Martial Reports as “Court Martial Reports.” (While that observation may seem pedantic, how much more pedantic can you get than the Bluebook?)

Similar to CAAF’s rules, the U.S. Court of Military Commission Review Rules of Practice provide, “Citations must conform to the style prescribed by the current edition of The Bluebook: A Uniform System of Citation published and distributed by the Harvard Law Review Association, unless otherwise directed by the CMCR. The CMCR, in its discretion, may adopt and publish its own rules of citation.” C.M.C.R. R. 15(e)(1) (lack of italicization in original). That requirement is somewhat amusing as the Bluebook continues to ignore the United States Court of Military Commission Review’s existence. You will not find a citation style for that court’s opinions, which are printed in West’s Federal Supplement.

The three DoD CCAs (but not the Coast Guard CCA) similarly generally prescribe adherence to the Bluebook, although the Air Force and Army Courts’ rules also refer to other military citation guides that often conflict with the Bluebook. See A.F. Ct. Crim. App. R. 17.1(a); A. Ct. Crim. App. R. 17.1(c); N-M. Ct. Crim. App. R. 17.2.

Changes in the Bluebook’s 22d edition include the creation of a new signal: “contrast” for use in “situations in which the contrast between authorities rather than a comparison between them will offer support for the proposition.” Another innovation is an official version of the popular “cleaned up” parenthetical: “‘citation modified’ to be used when a quotation has been stripped of internal quotation marks, brackets, ellipses, internal citations, and footnote reference numbers and capitalization has been modified without brackets.” See B.5.3. Rule 18 has been expanded to, inter alia, provide guidance for citing AI-generated content. Table T10 concerning geographical terms has been expanded. Please provide comments noting any additional important changes you identify. [Real names only, please. -- Ed.]

___

Dwight Sullivan is a senior counsel at the Air Force Appellate Defense Division and a professorial lecturer in law at the George Washington University Law School. The views expressed in this guest rant are those of the author and do not necessarily reflect the views of the Department of Defense or any of its components.

SCP website down?

The website of the Supreme Court of Pakistan seems to be inaccessible. If any reader has digital copies of the dissenting opinions in the Military Courts Case, please send them to the Editor or post a link in a comment. Global Military Justice Reform's rule against anonymity is hereby waived for this limited purpose.

The surving crew faced court-martial.

 

(With due consideration of Wikipedia's reliability.) There is an interesting story of HMS Alacrity and her loss to the French.

HMS Alacrity was a Cruizer-class brig-sloop built by William Rowe at Newcastle and launched in 1806. She served in the Baltic and was at the capture of Copenhagen in 1807. She captured a large privateer before herself falling victim to a French man-of-war in 1811 in an action in which her captain failed to distinguish himself. She then served in the French navy until she was broken up in 1822.

A newspaper account of the capture reported that when Palmer and Alacrity had sighted Abeille, Palmer had sent three boats to cut her out. However, the French had captured the cutting-out party. They then took the boats in tow and sailed towards Alacrity with English colours hoisted over the French, a ruse suggesting that the cutting-out party had succeeded in their mission. The French ran alongside Alacrity and carried her by boarding. Within a month of the battle Palmer died of tetanus from his otherwise minor wound. The court-martial of the survivors on 30 May 1814 attributed the loss to a lack of leadership. It acquitted all the survivors and commended the boatswain, James Flaxman, who had remained on deck though wounded and had attempted to rally the crew to Alacrity's defence.

As is British naval tradition, the Alacrity in name saw further service.

HMS Alacrity (F174) was active during the Falklands War of 1982, where she sank a supply ship, survived Exocet-missile attacks and rescued men from the Atlantic Conveyor. She was transferred to Pakistan on 1 March 1994 and renamed PNS Badr.

There does not appear to be an active Alacrity in Royal Navy service.

Forces Law Review (FLR)- the first global law journal on uniformed forces, now available! (Get Your Copy)

 

Volume-I (2025) of the Forces Law Review (FLR), the first international military law journal, is now available in hardcover all over the world through Amazon.

The FLR is a unique academic collaboration between the National Institute of Military Justice (NIMJ), Washington DC, USA and the Centre for Constitution & Public Policy (CCPP), University Institute of Legal Studies, Panjab University, Chandigarh, India. The journal covers matters related to the defence services and other uniformed forces such as the Police, the Paramilitary and the Armed Police Forces.

The journal carries the text, case-briefs and summaries of important judgments from all over the world principally from constitutional/appellate courts with precedential value and also carries a separate section on briefs of recent important developments on the subject, and another section for contributed opinion pieces approved by the editors.

The editorial oversight of FLR has been undertaken by three nominated Honorary Chief Editors and an Editorial Advisory Board comprising reputed personalities from the fields of law, judiciary and academia. Six Student Editors selected globally have assisted in the project.

Please support FLR and Get Your Copy here:  Amazon Link