Carrier on Special Verdicts

Christopher Daniel Carrier, The Possibility of Special Verdicts by Court-Martial Panels, 83 Mont. L. Rev. 1 (2022). 

"This article posits that a court-martial panel, unlike the jury in a civilian criminal trial, could be required by Congress to return a special verdict rather than a general verdict. The peer jury and the court-martial panel are now superficially very similar in function, but they differ in origin and authority such that legal and historical arguments about the powers of the jury
do not necessarily apply to the court-martial panel."