Collins v. McDonald
Headline: Affirmed denial of habeas relief for an Army private convicted by court‑martial abroad, holding robbery charges sufficiently described and military court had jurisdiction, so the prison sentence remains in force.
Holding:
- Makes it harder to overturn military court convictions on habeas petitions absent jurisdictional defects.
- Accepts 'taking from the presence' language as a sufficient robbery charge.
- Leaves the court‑martial sentence in place while other appeals proceed.
Summary
Background
A United States Army private, Roy Marshall, was tried by a court‑martial at Vladivostok, Siberia, convicted of robbery, and sentenced to imprisonment at McNeil’s Island. While waiting at the disciplinary barracks on Alcatraz, his attorney filed a habeas corpus petition in the federal district court in California challenging the conviction. The district court sustained the government’s demurrer, and Marshall appealed to this Court to determine whether the petition adequately alleged jurisdictional defects.
Reasoning
The Court framed the central question as whether the military tribunal had power over the soldier and over the offense charged. It held that the robbery specifications — accusing the defendants of putting victims in fear and feloniously taking money 'from the presence' of named persons — plainly described an offense under the federal robbery statute and therefore showed the court‑martial had jurisdiction. The Court explained that military charges need not use the technical language of common‑law indictments to be valid. The petition’s separate claim that the only evidence was a compelled confession was treated as an unsupported assertion about trial evidence and not a proper ground for habeas relief.
Real world impact
The ruling affirms the district court’s dismissal and leaves the soldier’s sentence intact. It reinforces that federal habeas petitions cannot overturn military trials except for clear jurisdictional failures, and it confirms that simple wording like 'from the presence' can be enough to charge robbery in military proceedings. This decision resolves only the procedural sufficiency of the petition and does not review trial evidence or decide guilt.
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