United States v. Howard is an example of the new practice of appeals in subjurisdictional cases. We will continue to refer to cases where the accused does not qualify for UCMJ art. 66 review as subjurisdictional cases.
[T]he court-martial members sentenced Applicant to reduction to E-5, forfeiture of $500.00 per month for three months, and confinement for 30 days.
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Joint R. App. Pro.
Army Crim. L. Deskbook