## Facts

- United States v. Duncan, 34 M.J. 1232 (A.C.M.R. 1992), is a published decision of the United States Army Court of Military Review (now the Army Court of Criminal Appeals).
- The case arose from a court-martial of an Army servicemember (Duncan) prosecuted by the United States under the Uniform Code of Military Justice (UCMJ).
- Duncan appealed his court-martial findings and sentence to the Army Court of Military Review for direct review under Article 66, UCMJ (as then in effect).
- The publicly accessible, non-paywalled record does not provide the charged offenses, the detailed factual events proved at trial, the sentence, or a complete list of assignments of error.
- Publicly accessible citations to the decision show that later military cases rely on *Duncan* (often citing 34 M.J. at 1246) when stating the standard for **legal sufficiency** of the evidence on appellate review.
- Those later citations indicate that *Duncan* discussed (and likely applied) the legal-sufficiency test that asks whether, viewing the evidence in the light most favorable to the prosecution, a rational factfinder could have found guilt beyond a reasonable doubt.
- Because the opinion’s full text is not available from open-access sources referenced here, additional specifics about the trial evidence, contested rulings, or the court’s full analysis cannot be stated reliably.

## Issues

1. What legal standard governs an Army appellate court’s review of the **legal sufficiency** of the evidence supporting a court-martial conviction (including whether the evidence is viewed in the light most favorable to the government and whether a rational factfinder could find guilt beyond a reasonable doubt)?
2. Applying that standard, was the evidence supporting Duncan’s conviction(s) legally sufficient?

## Decision

- The Army Court of Military Review issued a published opinion in *United States v. Duncan*, 34 M.J. 1232 (A.C.M.R. 1992).
- As reflected by how later military cases cite *Duncan*, the court stated the legal-sufficiency test consistent with the *Jackson v. Virginia* framework: viewing the evidence in the light most favorable to the prosecution and asking whether a rational factfinder could have found the essential elements beyond a reasonable doubt.
- The publicly accessible sources used to prepare this brief do not supply the opinion text, so the court’s case-specific application of that test and the precise disposition (for example, affirmed or modified) cannot be confirmed here without the reporter text.

## Legal Principles

- Legal sufficiency on military appellate review uses a *Jackson v. Virginia*-type inquiry: viewing the evidence in the light most favorable to the government, the question is whether a rational factfinder could have found all essential elements beyond a reasonable doubt.
- In the military justice system, service courts reviewing courts-martial under Article 66, UCMJ, address claims of legal error and may assess whether convictions satisfy legal sufficiency; the legal-sufficiency inquiry is distinct from any separate factual-sufficiency function those courts may perform under their statutory authority.
- A case may be reliably summarized for the legal proposition for which it is repeatedly cited (here, the legal-sufficiency standard), even when open sources do not provide the opinion’s full factual background or full disposition.

## Conclusion

*United States v. Duncan*, 34 M.J. 1232 (A.C.M.R. 1992), is an Army court-martial appeal best known in later citations for stating the military appellate standard for legal sufficiency of the evidence—asking whether, viewed in the light most favorable to the government, a rational factfinder could find guilt beyond a reasonable doubt—while the full factual narrative and exact case-specific outcome cannot be verified from the non-paywalled materials referenced here.


United States v. Duncan, 34 M.J. 1232 (1992)