CAAF has granted the petition in United States v. Brown, on a question that asks
ARE APPELLANT'S CONVICTIONS UNDER ARTICLE 91 LEGALLY INSUFFICENT WHERE THERE IS AN ABSENCE OF EVIDENCE THAT THE CHARGED CONDUCT OCCURRED IN THE SIGHT, HEARING, OR PRESENCE OF THE ALLEGED VICTIMS WHILE THEY WERE IN THE EXECUTION OF THEIR OFFICE?
The CGCCA published opinion is here.
"We hold that sending a disrespectful text message directly to the victim is actionable under Article 91, UCMJ."
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