## Facts

- Richard Solorio, an enlisted member of the U.S. Coast Guard, was accused of sexually abusing the minor daughters of fellow servicemembers.
- The alleged abuse occurred off base, in Solorio’s privately owned home in Alaska, during a prior Coast Guard tour.
- After Solorio transferred to New York, the Coast Guard convened a general court-martial in New York to try him under the Uniform Code of Military Justice (UCMJ).
- Solorio moved to dismiss the Alaska-related charges, arguing that, under then-existing precedent, military jurisdiction required the offenses to be “service-connected.”

## Issues

1. Whether a court-martial’s constitutional jurisdiction depends on the charged offense being “service-connected,” or instead depends solely on the accused’s status as a member of the Armed Forces.

## Decision

- The Supreme Court affirmed the judgment sustaining court-martial jurisdiction over Solorio.
- The Court held that court-martial jurisdiction depends solely on the accused’s military status at the time of the offense, not on any “service-connection” requirement.
- The Court expressly overruled O’Callahan v. Parker and rejected the “service-connection” framework associated with O’Callahan and later elaborated in Relford.
- The Court reasoned that Article I, § 8, cl. 14 gives Congress broad authority to regulate and govern the armed forces, and that the prior “service-connection” test was not supported by constitutional text, structure, or clear historical limits.
- The Court also emphasized the administrative and doctrinal confusion produced by the multi-factor “service-connection” analysis in military courts.

## Legal Principles

- Congress may authorize courts-martial to try offenses committed by members of the armed forces based on status alone under Article I, § 8, cl. 14.
- There is no constitutional requirement that a charged offense be “service-connected” for court-martial jurisdiction to exist.
- The jurisdictional inquiry focuses on whether the accused was a servicemember at the time of the offense, not on the offense’s location, victim status, or relation to military duties.
- Prior precedent imposing a service-connection limitation (O’Callahan) is no longer controlling.

## Conclusion

The Court held that military status is the sole constitutional basis for court-martial jurisdiction, overruling the service-connection limitation and permitting courts-martial to try servicemembers for offenses committed off base and unrelated to military duties.


Solorio v. United States, 483 U.S. 435 (1987)