Relford v. Commandant, US Disciplinary Barracks, Fort Leavenworth

Background

In 1961 a soldier stationed at Fort Dix was tried by court-martial for kidnapping and raping two women on the military reservation and was convicted and sentenced. One sentence of death was later reduced and the case became final after military review. Years later he filed habeas claims in federal court; the appeal reached the Supreme Court limited to how the earlier O'Callahan v. Parker decision applies. O'Callahan had held courts-martial could not try servicemen for crimes with no service connection when committed off post.

Reasoning

The key question was whether these crimes were "service connected" under O'Callahan so a military court could try them. The Court listed factors from O'Callahan and compared them to Relford's case. It found important differences: Relford was on the military enclave when the crimes occurred, one victim was performing duties at the post, automobiles on the base were forcefully entered, and the security and morale of the post were implicated. For those reasons the Court concluded the offenses were service connected and that the court-martial jurisdiction was proper, so the conviction stands.

Real world impact

The decision means military authorities may try servicemembers for crimes committed within the boundaries of a base that threaten people or property there. The ruling affects soldiers, commanders, and civilians who live or work on military posts by clarifying when military discipline can reach such offenses. The Court left undecided the outer limits of this rule and did not decide whether O'Callahan should apply retroactively to earlier cases.