The UK's Independent Inquiry Relating to Afghanistan has a user-friendly website here. Hats off to the Inquiry for going the extra mile on transparency, including translation into Dari and Pashto. "On 15 December 2022, the Government established an independent statutory inquiry to investigate matters arising from the deployment of British Special Forces to Afghanistan between mid-2010 and mid-2013. Lord Justice Sir Charles Haddon-Cave chairs the Inquiry."
Prof. Jack Goldsmith writes here about the "decaying legal culture" in the Defense Department. Excerpt:
Secretary of Defense Pete Hegseth came to office openly hostile to his department’s legal culture and determined to change it. He is succeeding. One result is persistent lawbreaking by the Department of Defense in derogation of the rule-of-law culture that the department has fostered since Vietnam. The courts, which have done an admirable job of checking the administration’s legal violations, cannot help here, since these matters are beyond judicial review. That leaves Congress, which, largely due to Republican control, has been sadly passive in Trump 2.0. When the reckoning comes, the Armed Services Committees in Congress will have a lot of explaining to do.
According to the Times, "[a]t least 12 high-ranking Russian military officials and generals, as well as dozens of lower-ranking officers, have been indicted on corruption charges in the past couple of years."
For more on the horror of serving in the Russian military today and those "meat grinder" assaults mentioned by the above-mentioned colonel, see this excellent and disturbing piece regarding Russian brutality vis a vis its own. I do believe how military treats its own has a correlation to how it treats its enemies and civilians .... brutality within encourages brutality to the external world.
This study addresses the problem of how differences in legal traditions influence the structure and enforcement of military law in Indonesia and Malaysia. It aims to examine and compare the legal foundations, institutional structures of military courts, and the characteristics of law enforcement applied to members of the armed forces in both countries. The research employs a normative juridical method with a comparative law approach by analyzing statutory regulations, particularly Law Number 31 of 1997 on Military Courts in Indonesia and the Armed Forces Act 1972 (Act 77) in Malaysia, as well as relevant legal literature and doctrines. The findings reveal that the principal differences between the two systems derive from their respective legal traditions—Civil Law in Indonesia and Common Law in Malaysia—which shape the organization of military courts, jurisdictional design, and procedural mechanisms for adjudicating military offenses. Indonesia relies on a codified and hierarchical military judicial structure, whereas Malaysia integrates common law principles within its court-martial system. Nevertheless, both systems share a fundamental objective, namely maintaining discipline, hierarchy, and command effectiveness within military institutions. In conclusion, despite structural and procedural distinctions, the military legal systems of Indonesia and Malaysia pursue similar normative goals. This study contributes to the development of comparative military law and offers a reference for strengthening military legal reform in Indonesia in alignment with the principles of the rule of law, military professionalism, and legal supremacy.
Some Estonian parliamentarians with military backgrounds are pressing to establish military courts for use in wartime, according to this report. Excerpt:
Under the plan, the national defense court would begin operating during a state of war. It would handle, under expedited procedure, all kinds of defense-related matters, including failure to report for mobilization, desertion, looting or the requisitioning of property.
Daimar Liiv, a member of the legal section of the Assembly of Reserve Officers and a judge at Tallinn Administrative Court, explained that the peacetime court system is too slow and thorough to resolve situations that arise during wartime.
"In wartime conditions, we cannot apply the same system of legal protection that we currently use through standard procedures. Decisions must be made quickly and judges must be prepared — not only morally, but also in terms of skills — to prepare such decisions. This is my professional assessment: judges currently operate in peacetime mode and cannot envision how this work should function under wartime conditions or whether the legislation is suitable," Liiv said.
This month, the Chair of Canada's Military Police Complaints Commission (MPCC), Tammy Tremblay, announced that our very own friend and colleague, Dr. Pascal Levesque, has joined the MPCC as a Part-Time Member. As many contributors and readers of the Global Military Justice Reform Blog are likely aware, Dr. Levesque is an accomplished scholar and lawyer. He served as a legal officer in the Canadian Forces for 15 years, serving in a number of roles. His LLM thesis examined the celerity of Canada's court martial system and his PhD was published as: Frontline Justice: The Evolution and Reform of Summary Trials in the Canadian Armed Forces (Montreal: McGill-Queen’s University Press, 2020).
Dr. Levesque has practiced law for over 30 years and served as chair of the Advisory Committee on Criminal Law of the Barreau du Québec from 2017 to 2020. Dr. Levesque will bring his knowledge, skill, and integrity to the MPCC, further reinforcing a statutory tribunal created to help ensure integrity and competence in military policing in Canada.
His bio with the MPCC can be found here:
Pascal Lévesque, Ph.D.
Congratulations, Pascal!
Above the Law reports here on the Defense Department's war on America's good law schools. Too woke? Excerpt:
Having watched the Department of Justice lose scores of career prosecutors and reduce itself to taking applications over DMs and bringing dance photographers out of retirement, the Department of Defense decided to get in on the action by cutting future military lawyers off from the country’s best law schools. You could say the DOD saw the DOJ become a national laughing stock of legal incompetence and said, “hold my beer,” except you can’t imagine Secretary of Defense Pete Hegseth putting down a beer that easily. Continuing the DOD’s performative anti-intellectual purge — which began with its public break with Harvard University — the Pentagon has informed active-duty service members that over 30 elite universities are now deemed “moderate to high risk” and therefore ineligible for DOD tuition assistance programs.
A panel of the U.S. Court of Appeals for the Fourth Circuit today upheld the Defense Department's prohibition on inducting applicants who test HIV-positive. Judge Paul V. Niemeyer wrote for a unanimous court in Wilkins v. Hegseth, No. 24-2079. Excerpt:
[S]ince the Military’s categorical prohibition on the entry of HIV-positive individuals into the Military passes rational basis review in several respects, such agency action is not arbitrary and capricious so as to violate the APA. The Military’s policy to deny HIV-infected persons from joining the Military well satisfies the rational basis review under the equal protection component of the Due Process Clause, particularly in the military context, when the Military is making a judgment about raising and supporting armies. . . .
In United States v. Matti, No. 25-0148 (C.A.A.F. Feb. 27, 2026) (per Maggs, J.), the U.S. Court of Appeals for the Armed Forces attached the following Appendix concerning improper argument by counsel:
Because of the persistent problem of trial counsel using improper arguments during courts-martial, the Court offers the following non-exhaustive compendium of instances when this Court has identified areas of concern. Perhaps it will provide some helpful guidance regarding the types of improper argument that trial counsel must avoid, that defense counsel should consider objecting to, and that military judges ought to monitor.
Improper Arguments in General
1. Expressing Personal Beliefs and Opinions. “It is improper for a trial counsel to interject herself into the proceedings by expressing a ‘personal belief or opinion as to the truth or falsity of any testimony or evidence.’ ” United States v. Fletcher, 62 M.J. 175, 179 (C.A.A.F. 2005) (quoting United States v. Horn, 9 M.J. 429, 430 (C.M.A. 1980)). This is because “ ‘when the prosecutor conveys to the [members] his personal view that a witness spoke the truth, it may be difficult for them to ignore his views, however biased and baseless they may in fact be.’ ” Id. at 180-81 (quoting United States v. Modica, 663 F.2d 1173, 1178-79 (2d Cir. 1981)).
2. Engaging in Improper Vouching. Vouching may “occur[] when the trial counsel ‘plac[es] the prestige of the government behind a witness through personal assurances of the witness’s veracity,’ ” including “the use of personal pronouns in connection with assertions that a witness was correct or to be believed.” Id. at 180 (second alteration in original) (quoting United States v. Necoechea, 986 F.2d 1273, 1276 (9th Cir. 1993)); see also United States v. Voorhees, 79 M.J. 5, 12 (C.A.A.F. 2019); Horn, 9 M.J. at 429-30 (improper to use phrase “I think” when “analyzing the evidence of record . . . and in suggesting what weight ought to be given by the court to various evidence” as such “opinions are merely a form of unsworn, unchecked testimony and tend to exploit the influence of his office” (citation modified)); United States v. Knickerbocker, 2 M.J. 128, 129 (C.M.A. 1977) (describing the following as “impermissible argument”: “ ‘I think that having listened to all of the evidence in this case, there is very little doubt, in fact in my mind there is no doubt whatsoever, that the man sitting over there at the defendant’s table . . . was in fact the individual who was involved in this matter as a principal.’ ”).
3. Offering Personal Views. Trial counsel cannot make “ ‘substantive commentary on the truth or falsity of testimony or evidence’ ” or “ ‘comment[] on the defendant’s guilt and offer[] unsolicited personal views on the evidence.’ ” Fletcher, 62 M.J. at 180 (first quoting United States v. Washington, 263 F. Supp. 2d 413, 431 (D. Conn. 2003); and then quoting United States v. Young, 470 U.S. 1, 7 (1985)). Such comments “may confuse the [members] and lead them to believe that the issue is whether or not the prosecutor is truthful instead of whether the evidence is to be believed.” Id. at 181 (citing Modica, 663 F.2d at 1181).
4. Referring to Matters Outside the Record. When trial counsel departs from record evidence, “an accused’s right of confrontation [is] abridged, and the opportunity to impeach the source [is] denied.” United States v. Clifton, 15 M.J. 26, 29 (C.M.A. 1983). This misconduct manifests in a variety of scenarios. See, e.g., United States v. Norwood, 81 M.J. 12, 21 (C.A.A.F. 2021) (“Arguing an inflammatory hypothetical scenario with no basis in evidence amounts to improper argument . . . .”); Clifton, 15 M.J. at 30 (critiquing “discours[ing] on the practices and fantasies of rapists, and . . . the attitudes of unrelated rape victims”).
5. Commenting on the Accused’s Invocation of Constitutional Rights. “[I]t is improper for a prosecutor to ask the court members to infer guilt because an accused has exercised his constitutional rights.” United States v. Carpenter, 51 M.J. 393, 393 (C.A.A.F. 1999).
A Philippine Army officer will face a general court-martial under the country's equivalent to Article 88 of the Uniform Code of Military Justice. According to this account in the Manila Bulletin, Colonel Audie Mongao (left) posted on social media his withdrawal of support from President Ferdinand Marcos Jr.
Lt. Gen. Antonio Nafarette, PA commanding general, said he already approved general court martial proceedings to try Mongao for alleged violation of Articles of War 63 which penalizes “disrespect toward the President, Vice-President, Congress of the Philippines, or Secretary of National Defense.”
Article of War 63 states that any officer who uses contemptuous or disrespectful words against the President, Vice-President, the Congress of the Philippines, or Secretary of National Defense, “shall be dismissed from the service or suffer such other punishment as a court-martial may direct.”
It's Sunday morning here in the glass-enclosed newsroom high above Global Military Justice Reform Plaza, and the weekend staff is trying to figure out the "Yeye culture" problem -- is it a problem? -- in the Malaysian armed forces. For readers' edification, consider this YouTube video from Victor Tan and this news report from the Straits Times. Watch the video first.
Dr. Ellen Nohle's OpinioJuris essay, Reforming Military Obedience: Strengthening Vertical Checks on Trump's (Ab)use of War Powers, concludes:
Possible concerns that increasing soldiers’ legal privilege to refuse ultra vires orders would undermine a nation’s ability to defend itself militarily is belied by psychological research showing that soldiers fight primarily out of regard for their comrades and superiors, not out of a sense of legal compulsion . In fact, research on compliance with orders shows that ordinary people tend to err on the side of obedience rather than disobedience, even in the absence of a legal duty to obey. In light of that, the function of the law should be to help and incentivize soldiers to identify and challenge abuses of war powers, not punish those who have the moral courage to resist the potent socio-psychological pressures to comply with orders irrespective of their legality.
Still, the redistribution of trust entailed by granting soldiers a right to disobey ultra vires orders will no doubt come up against some deep-rooted assumptions, and opposition to the proposal is to be expected. The assumption in the military has long been that trust must be distributed along the hierarchy of command. Absolute trust, in the form of decision-making power, is vested in the president as commander in chief, and subordinate commanders are trusted based on their relative position in the military hierarchy. Although the military in many ways operates as a separate community, legally and socially, from the rest of society, the military’s existence and powers derive from the civilian government and its functions are defined by civilian-made laws and policies. The economy of trust in the military must therefore ultimately bend to the economy of trust in civilian society. A rule requiring absolute trust in the commander in chief is incompatible with the limited institutional trust, or decision-making powers, vested in the president as chief executive. If uncritical obedience has no place in a government ruled by law, then neither does it have a legitimate place in the government’s executive arm, the military.
Dr. Nohle is a senior legal advisor at the IHL Centre.
Military justice reform in Lebanon remains a challenge, particularly regarding judicial independence and jurisdiction over civilians. This article gives the history but is unclear as to precisely what changes are being made and when they may take effect. The Legal Agenda posted this worthwhile commentary earlier this month. The Cedar Centre for Legal Studies has issued this extensive report by Dr. Marie Kortam. According to the executive summary:
In the ongoing debate among politicians and human rights activists regarding the reform of the military justice and its jurisdiction, the law continues to allow civilians to be tried before military courts. Such trials deprive civilians of essential judicial safeguards, as military judges often fail to provide explanations for their decisions, thereby shielding the judiciary from meaningful legal oversight. This debate is divided between two main positions. One advocates for abolishing military justice in civilian cases entirely, limiting its scope to disciplinary matters involving military personnel (Legal Agenda, 2024). The other argues for reconstituting military courts with justices of the peace, rather than military officers, to enhance fairness and transparency (Boutros, Saghiyeh, 2018).
This report discusses these paradoxes by contextualizing the debate within its historical and legal framework. It draws on desk reviews and interviews with lawyers and human rights defenders, alongside an analysis of four case studies highlighting violations and the lack of conformity within military courts. Based on these findings, the report proposes recommendations aimed at ensuring a minimum standard of fairness in military court proceedings. It is of note that civilians standing trial before military courts violate international standards. The Decaux Principles (Callejon, 2006; Weill, Sharon, Robinson, Mitch (2017) prohibit the trial of civilians by military courts and extend to specific offenses committed by members of the military and security forces, even when performed in the line of duty.
Any reader with knowledge of the precise state of play is welcome to comment.
Dr. Kizza Besigye and an aide have filed a new case with Uganda's Constitutional Court. According to this report, they contend that the court-martial is unconstitutional because its members are serving officers who lack protected tenure and remain subject to military discipline.
The government has proposed significant changes in New Zealand's military justice system. Here is the Defence Ministry's press release:
Legislation to modernise the military justice system has passed its first reading today, Defence Minister Judith Collins says.
“The Armed Forces Discipline Law Amendment Bill modernises New Zealand’s military justice system so that it is fairer, more efficient, and more transparent,” Ms Collins says.
“The Bill will make our system easier to navigate, allowing commanders to focus on operational readiness in an increasingly volatile world.”
“The current military justice system is out-of-date, with no substantial changes made since 2007. These updates align it more closely with developments in the civilian justice system.
The Bill will introduce a Minor Discipline Sanction System for very low-level offending, such as being late for duty, avoiding the need for a Summary Trial. Serious, complex and sensitive offending will follow a new streamlined and independent pathway to Court Martial, overseen by the Director of Military Prosecutions.
New search powers will increase the New Zealand Defence Force’s ability to investigate alleged offending, while providing better protections for those subject to them. These include the power for officers in charge of Defence Areas to authorise searches within those areas, and for judicial warrants to be sought for sensitive searches of electronic devices and areas outside Defence Areas, aligning with Bill of Rights Act requirements.
The Bill extends the right to elect trial by Court Martial to most offences and introduces a new power to drug test members of the Armed Forces for disciplinary purposes.
“Our Armed Forces must maintain strong discipline so they are always ready to protect New Zealanders,” Ms Collins says.
“We hold our personnel to a high standard and they should expect the same from their military justice system.”
The supporting Explanatory Note and the bill text can be found here.
The key substantive changes made by the Bill are as follows:
- creation of a new minor disciplinary sanction system, which will provide a faster, more efficient, and more transparent way of dealing with very low-level offending (such as being late for duty):
- transfer of responsibility for serious, complex, or sensitive offending out of the chain of command to the Director of Military Prosecutions:
- extension of the right to elect trial by the Court Martial to all offences except for a subset that will be identified in Defence Force Orders:
- updating the existing search power under section 95 of the Armed Forces Discipline Act 1971, together with the creation of new powers to search defence areas and carry out drug testing:
- establishment of a new search warrant framework providing judicial oversight of searches of electronic devices and providing new powers for a Judge to authorise the New Zealand Defence Force Joint Military Police Unit to search areas outside of a defence area owned, occupied, or used by a member of the Armed Forces, or to request documents from third parties:
- better alignment of bail provisions with those that apply in the civilian criminal justice system under the Bail Act 2000:
- provision for the Director of Military Prosecutions to appeal against certain summary trial decisions, in line with the appeal rights available to prosecutors in the civilian criminal justice system under the Criminal Procedure Act 2011:
- updating of powers to address disruptive behaviour and contempt of court to better align with the Contempt of Court Act 2019:
- application of the special procedures in Part 2 of the Security Information in Proceedings Act 2022 to certain proceedings in the Court Martial and Court Martial Appeal Court.
Yesterday's decision by Judge Richard J. Leon in Kelly v. Hegseth can be found here. Here's the lede:
United States Senator Mark Kelly, a retired naval officer, has been censured by Secretary of Defense Pete Hegseth for voicing certain opinions on military actions and policy. In addition, he has been subjected to proceedings to possibly reduce his retirement rank and pay and threatened with criminal prosecution if he continues to speak out on these issues. Secretary Hegseth relies on the well-established doctrine that military servicemembers enjoy less vigorous First Amendment protections given the fundamental obligation for obedience and discipline in the armed forces. Unfortunately for Secretary Hegseth, no court has ever extended those principles to retired servicemembers, much less a retired servicemember serving in Congress and exercising oversight responsibility over the military. This Court will not be the first to do so!
A Brazilian court is considering whether former President Jair Bolsonaro and several senior officers should be dismissed for attempting a coup Excerpt from this report:
Brazil's Superior Military Court (STM) notified former president Jair Bolsonaro and three other generals, already convicted for the attempted coup against current head of state Luiz Inácio Lula da Silva, on Tuesday, thus beginning the judicial proceedings stemming from allegations of unworthiness raised in early February by the Military Prosecutor's Office for their participation in the coup plot.
“Former President Jair Bolsonaro and Army Generals Paulo Sérgio Nogueira, Augusto Heleno, and Braga Neto have been summoned by their respective investigating judges to submit their written defenses within ten business days from the date of the summons,” the STM reported on its website regarding the retired military officers sentenced by the civil courts to prison terms of 27, 19, 21, and 26 years, respectively.
The court has emphasized that this summons "marks the beginning of the process, as it concludes the preliminary phases and gives way to the formal statement of the accused."
* * *
The initiative presented by the military attorney general, Clauro Bortolli, called Representation for Declaration of Unworthiness for the Officer Corps, is the mechanism by which the Military Justice must decide whether a member of the Armed Forces sentenced to more than two years in prison, for military or common crime, maintains or does not maintain the necessary condition to continue being part of the officer corps.
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Nigerian military officers stand accused of plotting a coup. Court-martial or civilian trial? Femi Falana SAN says it cannot be a military trial. This article explains why. Excerpt:
“Since the indicted civilians are not subject to service law, they cannot be tried in a military court,” he said.
“Even in the case of Chief Moshood Kashimawo Olawale Abiola v The Federal Republic of Nigeria (1995) 1 NWLR (Pt.370) 155, the defendant was charged with treasonable felony at the Federal High Court. Similarly, in the case of Ameh Ebute v State (1994) 8 NWLR (Pt 360) 66, the defendants including Senator Ahmed Bola Tinubu (now President) were charged with treason at the Federal High Court.”
The lawyer recalled several landmark rulings, including the 2025 Supreme Court decision in Uganda, which declared that military courts lack jurisdiction to try civilians.
He said, “The illegal practice of prosecuting civilians in military courts has just been stopped by the Supreme Court of Uganda in the case of Dr. Kizza Besigye & Another v Attorney General & Another (Miscellaneous Cause 31 of 2025) [2025] UGHCCD 29 (24 February 2025).
The National Lawyers Guild's Military Law Task Force has issued this position paper "in defense of Sen. Mark Kelly." Excerpt:
[Pete] Hegseth’s more recent use of administrative action , threatening to demote Kelly and reduce his veteran’s benefits, is a retreat from earlier threats to prosecute Kelly, for ‘contemptuous speech” under the rarely-used Article 88. When those threats were made, we were confident that a trial was unlikely, given that career military prosecutors are JAGs, well versed in what UCMJ covers. They’d know that the Army Court of Criminal Review ruled in 1969: “As a matter of law, an order of a subordinate which contravenes the Constitution, a federal statute, a presidential executive order, a departmental regulation or other lawful directive of higher authority can have no lawful validity,” (US v Patton, U.S.A.C.M.R. 1969). And a century earlier, the US Supreme Court pointed out: “A soldier cannot justify on the ground that he was obeying the orders of his superior officer” if “a person of ordinary intelligence would know that obedience would be illegal and criminal.” Dow v. Johnson, 100 U.S. 158, 189 (1879).That same decision adds that “the established principle of every free people is, that the law shall alone govern; and to it the military must always yield.”
And those JAGs would know that servicemembers and veterans are protected by the First Amendment’s free speech provisions, as highlighted by the National Institute [of] Military Justice: “Although the military code criminalizes certain types of speech that may affect the military mission, the Senator’s remarks are far from criminal. He simply restated a fundamental principle of military law: service members must obey lawful orders and disobey unlawful orders.”
After years of preparation, the Botswana Defence Force has an updated military justice system. The new system is outlined in this video.
El País has this report on yet another disciplinary case from Spain's Guardia Civil. To set the stage:
It all happened on April 1, 2022. The officer, who was in charge of guarding the gym at the Prime Minister's Office Security Department, was on the afternoon shift. Before starting work, he ate some tapas and drank two beers in the cafeteria. While he was at his post, two colleagues arrived with a bottle of gin, which the three of them drank with Coca-Cola. Thus, the Civil Guard officer "not only allowed the introduction and consumption of alcohol in the gym, but also participated in its consumption," the court emphasizes. Four hours later, around 7:15 p.m., two other uniformed officers arrived, including Sánchez's then-head of security. By then, the sanctioned officer already showed clear signs of having consumed excessive amounts of alcohol. In fact, without the ruling describing any trigger, the officer "lowered his trousers and exposed his buttocks, while dancing and squatting."
What punishment would you impose?
IN THE UNITED STATES COAST GUARD COURT OF CRIMINAL APPEALS
UNITED STATES, Appellee
v.
Randy J. GALLIANO, Seaman Apprentice (E-2), U.S. Coast Guard, Appellant
Docket No. 1514
ORDER TO REPRESENT APPELLANT
On 8 September 2025, Appellant was convicted at special court-martial and sentenced to reduction to E-1 and a bad-conduct discharge. The case was referred to this Court on 20 November 2025.
On 15 January 2026, Appellate Defense Counsel filed a Notice of No Authority to Represent Appellant, asserting that she had been unable to contact Appellant and did not “intend to file any substantive pleading before this Court.”
Article 65 of the Uniform Code of Military Justice (UCMJ) directs that the record of trial of a case in which a bad-conduct discharge has been adjudged be forwarded to the Court of Criminal Appeals for review under Article 66(b)(3), UCMJ. Article 70, UCMJ, requires that appellate defense counsel be detailed and shall represent an accused before the Court of Criminal Appeals when requested by the accused or when the United States is represented by counsel. The appellate rights notice in the record of trial, acknowledged by Appellant’s signature, states that military counsel will be appointed to represent him. Rule 11 of the Joint Rules of Appellate Procedure provides, “Upon docketing of a case, the appropriate Judge Advocate General or designee shall, unless previously done, designate appellate military counsel to represent the parties . . .” Thus the United States, as well as the accused, is represented in every case before the Court of Criminal Appeals.
In these circumstances, counsel’s authority to represent Appellant stems not solely from the client’s direction or consent but also from counsel’s military duty upon being detailed. This conclusion is supported by United States v. Sink, 27 M.J. 920, 921 (A.C.M.R. 1989) (“[C]ounsel contends that he is precluded from representing the appellant on appeal because he cannot establish an attorney-client relationship with him . . . . We disagree. . . . [His] duty of representation can be met effectively in most cases without the appellant’s knowledge or active participation.”); United States v. Harper, 80 M.J. 540, 542 (N-M Ct. Crim. App. 2020) (“Given . . . the lack of any affirmative action by Appellant either to waive his right to representation or to withdraw his case from appellate review, we conclude that appellate defense counsel not only has the authority, but is statutorily required to represent Appellant, to the best of her ability, notwithstanding her inability to locate or communicate with him.”); United States v. May, 47 M.J. 478, 481-82 (C.A.A.F. 1998) (“Where individual civilian counsel's failure to act is working to the detriment of an appellant, military appellate counsel may not stand by idly, because they remain responsible for protecting the interests of their client. * * * As officers of the court as well as appellate defense counsel, military counsel had an obligation to . . . protect the interests of their client.”)
Accordingly, it is, by the Court, this 22nd day of January 2026,
ORDERED:
That Appellate Defense Counsel shall represent Appellant and file assignments of error and brief not later than thirty days from the date of this order.
Is this Order correct? If you were SA Galliano's appellate defense counsel, what would you do in light of it?
