- Court: United States Supreme Court
- Area(s) of Law: Criminal Law
- Date Filed: December 10, 2020
- Case #: 19-108
- Judge(s)/Court Below: ALITO, J., delivered the opinion of the Court, in which all other Members joined, except BARRETT, J., who took no part in the consideration or decision of the cases. GORSUCH, J., filed a concurring opinion.
- Full Text Opinion
Respondents were charged with rape under the Uniform Code of Military Justice (UCMJ) when rape was punishable by death and therefore no time limit for bringing charges applied. Respondents argued that, because rape was not punishable by death in civilian courts under Coker v. Georgia, 433 U. S. 584, 592 (1977), the applicable statute of limitations for their rape charges was five years. The Court of Appeals for the Armed Forces (CAAF) held that the five-year statute of limitations applied and barred Respondents’ rape convictions. On appeal, the Supreme Court of the United States reversed, holding that there was no time limit on the rape prosecutions. The Supreme Court reasoned that the phrase used in the UCMJ—"punishable by death”—applies to crimes punishable by death in the UCMJ, not all applicable law. The Supreme Court gave three reasons for this interpretation. First, the UCMJ is a uniform code, so it was “natural” for it to refer to itself. Second, since statutes of limitations typically provide clarity, it was unlikely Congress intended to refer to all applicable law. Finally, the Supreme Court declined to assume that Congress tied the UCMJ’s statute of limitations to the Court’s Eighth Amendment decisions. REVERSED and REMANDED.