Summary
The Supreme Court considered whether a naval court-martial had jurisdiction to try a paymaster's clerk and whether it could revise an initial sentence before dissolution. The Court held that the petitioner was in the naval service, that the revised sentence was authorized, and that habeas corpus could not correct mere errors or irregularities where the court-martial had jurisdiction. The application for discharge was denied.
Topics
Practice areas
Questions Presented
- Whether a regularly appointed paymaster's clerk was a person in the naval service subject to trial by naval court-martial.
- Whether the court-martial's authority was exhausted when it first pronounced sentence, making the revised sentence void.
- Whether the court-martial could revise its sentence only to correct a mistake, and whether the revised sentence was therefore unauthorized.
- Whether habeas corpus could discharge Reed based on alleged errors or irregularities in the court-martial proceedings.
Holdings
- A regularly appointed paymaster's clerk is a person in the naval service of the United States and is subject to trial, conviction, and sentencing by a naval general court-martial for offenses within the governing statutes.
- A court-martial may revise its proceedings and sentence when directed to do so by the authority that ordered the court, provided the court is reconvened before dissolution and the revised sentence is approved as required.
- A court-martial judgment approved as required cannot be collaterally impeached on habeas corpus for mere error or irregularity committed within the court's lawful authority; relief is available only when the sentence is absolutely void for lack of jurisdiction.
Key quotations
“Such regulations have the force of law.” (22)
“Having had such jurisdiction, its proceedings cannot be collaterally impeached for any mere error or irregularity, if there were such, committed within the sphere of its authority.” (23)
“A writ of habeas corpus cannot be made to perform the functions of a writ of error.” (23)
“To warrant the discharge of the petitioner, the sentence under which he is held must be, not merely erroneous and voidable, but absolutely void.” (23)
Factual background
Alvin R. Reed was a duly appointed clerk to a paymaster in the United States Navy and had agreed in writing to submit to naval laws and regulations. He was convicted by a naval general court-martial of malfeasance, but the convening admiral returned the sentence for revision before the court was dissolved. The court-martial substituted a more severe sentence, which the admiral approved, and Reed was confined under it aboard a naval vessel in Boston.
Procedural history
Reed, a paymaster's clerk in the United States Navy, was convicted by a naval general court-martial and sentenced. After the convening officer returned the original sentence for revision, the court-martial imposed a more severe substitute sentence, which the admiral approved. Reed sought habeas corpus in the Circuit Court for the District of Massachusetts, which denied relief and remanded him to custody. The Supreme Court denied his application.