Stanley v. J L Jamison

Background

Aaron R. Stanley filed a petition under 28 U.S.C. § 2241 challenging his conviction by general court-martial and resulting confinement. He asked the court to order a new trial or release him. Stanley had been convicted of premeditated murder and several other offenses by a military court and was sentenced to life imprisonment without parole and a dishonorable discharge. The Army Court of Criminal Appeals affirmed the findings and sentence, and the Court of Appeals for the Armed Forces affirmed the military judge’s self-defense instruction. The Supreme Court later denied review.

Stanley initially asserted four grounds for relief. The court treated his amended petition as the operative pleading and considered the other claims abandoned. The amended petition raised two due-process claims concerning Dr. Christian DeGregorio, the mental-health expert appointed for Stanley’s defense. Stanley argued that Dr. DeGregorio did not meaningfully examine him for post-traumatic stress disorder or assist with his defense, and that DeGregorio was not sufficiently independent because he was an Army member assigned to the same post as the prosecutors and subject to the same post commander.

Legal standard

Federal review of a military conviction through a habeas petition is limited. The court explained that a civilian court generally asks whether the military courts gave the petitioner’s claims full and fair consideration. A claim ordinarily cannot be reviewed if the petitioner failed to raise it in the military courts or failed to exhaust available military remedies. To overcome that procedural default, the petitioner must show cause for the failure and resulting prejudice. The court also applied the rule that filings by a person without a lawyer are read liberally.

Meaningful-examination claim

The court distinguished between Stanley’s earlier challenge to whether Dr. DeGregorio was qualified to be appointed and his amended claim that DeGregorio’s actual examination and assistance were inadequate. The court found that Stanley had not raised the meaningful-examination claim on appeal. It was not persuaded that a reference in a clemency request saying that Stanley had not been adequately evaluated showed that the military courts had fully and fairly considered the claim.

The court then considered whether Stanley had shown cause to excuse the procedural default. Stanley argued that he did not learn of the allegedly deficient examination until he received a post-traumatic-stress-disorder diagnosis in 2021. The court found, however, that Stanley and his counsel had already questioned DeGregorio’s qualifications and the adequacy of his evaluation during the court-martial proceedings, the clemency process, and the appeal. Because Stanley did not establish cause, the court held that the claim was procedurally barred and did not review its merits.

Independence claim

The court also held that Stanley’s claim concerning DeGregorio’s independence was procedurally barred. Stanley had not raised this particular conflict theory in the military courts and provided no justification for that failure. The court noted that Stanley had raised other concerns about DeGregorio’s conflicts on appeal and that the facts underlying the new claim—DeGregorio’s Army affiliation, assignment, and association with the prosecution and post commander—were known to Stanley at trial.

The court rejected Stanley’s argument that the constitutional nature of the claim made the ordinary waiver and exhaustion rules inapplicable. It explained that the cited authority did not eliminate the requirement that military courts first be given an opportunity to consider the alleged error. The court therefore declined to review the independence claim on its merits.

Disposition

The court denied Stanley’s § 2241 petition in its entirety and dismissed the action. It declined to issue a certificate of appealability because Stanley had not made a substantial showing that a constitutional right was denied. The Clerk was directed to terminate open matters and close the case.