Ramos is "retroactive." Yes, that is what the highest court in Oregon concludes in Watkins v. Ackley, under Oregon law.
 See footnote 2 discussing why the term retroactive is misleading.
We have posted before about Presidential Pardons and military persons (mostly former) getting one.
Today, President Biden pardoned one servicemember convicted at court-martial.
What is interesting is he served on active duty after his conviction. Some of us remember when there was a Return-to-Duty program that was used and mostly worked.
Vincente Ray Flores-Air Force-Reduction in rank to grade E-3 (as amended); forfeiture of $700 pay per month for four months; confinement for four months, suspended for participation in the Air Force Return to Duty Program (May 16, 2008) Wrongfully using 3,4 methylenedioxymethmaphetamine; underage drinking.
CNN reports that
Vincente Ray Flores was court martialed when he was around 19 for consuming ecstasy and alcohol while serving in the military. After being sentenced to four months confinement, he participated in a return-to-duty program and remains on active duty, earning various honors from the military.
Why care about Wisconsin v. Bowers?
The Appellant, a police officer, created a DropBox account using his police department email address--duh.
He then used the DropBox to transfer documents or give access to specific folders to others--sharing.
He then put police reports of several murder investigations into the folders for others to have access to.
The police were not happy that the investigations fell into the wrong hands and soon learned about the DropBox account.
Because it was an "official account" the IT folks simply accessed the DropBox account. When the went to log in they arlready had the email address so all they had to do was click "forgot password" and whamo--they get to reset the password. Apparently Bowers wasn't using 2FA--duh.
Having gotten access, the IT folks and the prosecutor soon found what they were looking for. But, not so fast, the search was all done without a warrant. That's why Bowers is an interesting case to read about a reasonable expectation of privacy in a DropBox account where there is sharing.
The critical word saving Bower on appeal is "password."
And may you be having fair winds and following seas for 2023.
Military Justice Reform: The Next Twenty Years
Disclaimer: Posts are the authors' personal opinions and do not reflect the position of any organization or government agency.
-Current Term Opinions
Joint R. App. Pro.
Army Crim. L. Deskbook