United States v. Navarro · ARMY 20250171 · Army Court of Criminal Appeals · March 30, 2026
An Army Specialist pleaded guilty to possessing child pornography under Article 134 of the UCMJ. His defense lawyer negotiated a plea deal that kept him out of prison entirely. The only punishment: a bad-conduct discharge. No confinement. No additional penalties. For this type of charge, that outcome stands out as remarkably favorable.
A change to Article 66, UCMJ, has created difficulties in interpreting and applying the factual sufficiency standard of review and in deciding whether a charge should be set aside. Note: this change only affects cases where ALL findings of guilt are based on conduct alleged to have been committed before 1 January 2021. If it’s a bridge case — convictions for an offense both before and after 1 January 2021 — the old rule applies. Call Cave & Freeburg, LLP, at (703) 298-9562 or (917) 701-8961 to discuss your case.
If you were convicted at a court-martial, one fact could shape your entire appeal: the date the alleged offense occurred. Not the date of your trial. Not the date you were sentenced. The date of the offense itself.
In re LB, Misc. Dkt. No. 2025-14
The First Amendment follows you into uniform, but it does not follow you the same way. Service members who do not understand where the line falls often cross it without knowing—and pay with their careers. This informational post is brought to you by Cave & Freeburg, LLP, at court-martial.com.
The answer is more complicated than most service members realize, more consequential than most civilians understand, and more unsettled than any branch would prefer to admit. The stakes—careers, pensions, liberty—demand that every service member know the terrain before they speak.
Court: Navy-Marine Corps Court of Criminal Appeals Panel: Senior Judge Gross (author), Chief Judge Daly, Judge de Groot Result: Affirmed
In January 2026, a federal grand jury in the Eastern District of Virginia indicted Army soldier James Isaac Guinsler on four counts of coercion and enticement of a child and one count of possession of child pornography. The case began when Snapchat’s automated system flagged two images of child sexual abuse material (CSAM) that Guinsler shared on April 29, 2024. The York-Poquoson Sheriff’s Office traced the Snapchat account to Guinsler through T-Mobile records, then obtained warrants for his Snapchat and iCloud accounts — both limited to a two-month window (April–May 2024). Those searches uncovered sexually explicit conversations with multiple females who identified themselves as minors.
On March 25, 2026, the United States Army Court of Criminal Appeals issued its decision in United States v. Williams-Clark (ARMY 20230185). The court set aside a sexual assault conviction — one that carried a two-year confinement term — not on the merits, but because the verdict itself was fatally ambiguous. The military judge convicted Private Williams-Clark of sexual assault without consent while simultaneously acquitting him of sexual assault when the victim was incapable of consenting. Both specifications covered the same day, the same location, and the same victim — but two separate sexual acts.
The court could not determine which act formed the basis of the conviction. That uncertainty, the court held, made meaningful appellate review impossible. The conviction had to go.
Published by Cave & Freeburg LLP | Military Justice Defense Attorneys
Case Citation: United States v. Castillo, No. ACM 40705 (A.F. Ct. Crim. App. Mar. 11, 2026) | Unpublished
A recent Air Force Court of Criminal Appeals decision — United States v. Castillo — raises an important question every military defense lawyer must understand: when does a military judge have a duty to instruct on an affirmative defense, even during a guilty plea proceeding? The answer directly affects court-martial strategy, plea negotiations, and appellate rights for servicemembers facing charges under the Uniform Code of Military Justice (UCMJ).
The Navy-Marine Corps Court of Criminal Appeals (NMCCA) decided United States v. Selleneit on 17 March 2026, affirming the findings and sentence of a general court-martial tried at Naval Station Rota, Spain. Fire Controlman Aegis Petty Officer Second Class (E-5) George B. Selleneit faced charges of sexual assault under Article 120, UCMJ, and unlawful entry under Article 129, UCMJ. A panel of officer and enlisted members acquitted him of sexual assault but convicted him of unlawful entry. The court sentenced Selleneit to reduction to E-3, restriction to USS Porter for two months, and forfeiture of all pay and allowances for two months (with the convening authority waiving forfeitures above two-thirds pay per month).
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