United States v. Levani J. Eneliko — CAAF (Oct 7, 2026)
The Court of Appeals for the Armed Forces considers whether a Navy sailor's confession was properly used to convict him of cocaine use. After a positive urine test, he was escorted from a mental health appointment to questioning by criminal investigators. Before advising him of his rights, a detective told him they could not help him unless he told them what happened. He then received warnings, agreed to talk, and admitted using cocaine. Article thirty-one Bravo requires military interrogators to explain the accusation, the right to remain silent, and that statements can be used against the suspect. The defense sought to exclude the confession, saying the investigators had misled him. The trial judge admitted it, convicted him, and reduced him by one pay grade. The Navy-Marine Corps Court of Criminal Appeals set aside the conviction and sentence and authorized a new trial. It found the judge's analysis insufficient, without deciding whether the sailor's waiver of rights was valid. The government brought that ruling here for review. The dispute concerns whether the judge adequately examined both free choice and understanding of the rights, and whether the defense preserved that second issue at trial. Captain Jacob Carmin, of the Marine Corps, will speak for the government. He will defend the judge's analysis and contend that the defense failed to raise the understanding issue at trial.
United States v. Levani J. Eneliko (No. 26-0138/NA) — United States Court of Appeals for the Armed Forces, argued October 7, 2026.
- 0:00Introduction
- 18:24Advocate — Raymond Bilter