## Facts

- Steven R. Oramas was a permanent-party soldier who worked as a medical-care specialist at an Army installation aid station.
- Oramas’s duties included treating Initial Entry Training (IET) soldiers who came to the aid station for medical care.
- While interacting with IET soldiers seeking treatment, Oramas flirted with and made inappropriate, unsolicited advances toward three IET soldiers.
- Each of the three IET soldiers either ignored or rebuffed Oramas’s advances.
- The government charged Oramas with violating Army Regulation (AR) 600-20, described as a general regulation that prohibits permanent-party personnel from engaging in nonprofessional relationships with IET soldiers.
- Oramas pleaded guilty.
- During the providence inquiry, Oramas admitted making advances toward each of the three IET soldiers and that each rejected him.
- The military judge accepted the guilty plea, and the convening authority approved the findings.
- The case was then sent to the United States Army Court of Criminal Appeals for review under Article 66 of the Uniform Code of Military Justice.

## Issues

1. On Article 66 review, whether Oramas’s guilty plea was supported by an adequate factual basis, based on his admissions about unsolicited advances toward IET soldiers and their rejection of those advances.
2. Whether the admitted conduct could constitute a violation of AR 600-20’s prohibition on nonprofessional relationships between permanent-party personnel and IET soldiers.

## Decision

- The military judge accepted Oramas’s guilty plea after a providence inquiry in which Oramas admitted making unsolicited advances toward three IET soldiers and being rebuffed.
- The convening authority approved the findings, and the case proceeded to the United States Army Court of Criminal Appeals for mandatory review under Article 66, UCMJ.
- The publicly available case information provided here does not include the Army Court of Criminal Appeals’ full written disposition or its reasoning.

## Legal Principles

- A service member may be convicted under Article 92, UCMJ, for violating a lawful general regulation when the regulation applies to the member and the member’s conduct falls within the regulation’s prohibition.
- A military judge may accept a guilty plea only if the record of the providence inquiry establishes a factual basis for each element of the offense and the accused’s admissions are consistent with guilt.
- Article 66 review by a service Court of Criminal Appeals includes appellate review of court-martial cases that meet statutory requirements, including review of the record in guilty-plea cases.
- AR 600-20 is described in this case as prohibiting permanent-party personnel from engaging in nonprofessional relationships with IET soldiers.
- Admissions that a permanent-party medical-care specialist made inappropriate, unsolicited advances toward IET soldiers in the context of providing official medical services are relevant to whether the accused’s conduct was nonprofessional within the meaning of the regulation.

## Conclusion

United States v. Oramas concerns a permanent-party Army medical-care specialist who pleaded guilty to violating AR 600-20 after making inappropriate, unsolicited advances toward three IET soldiers seeking medical treatment, each of whom ignored or rejected the advances; the guilty plea was accepted at trial, the findings were approved by the convening authority, and the case was sent to the Army Court of Criminal Appeals for Article 66 review, though the provided public materials do not include the court’s complete written disposition or analysis.


United States v. Oramas, 2007 WL 7271934 (2005)