Overview of counsel qualifications:
1. GCM. Article 27(b), UCMJ. “Trial counsel . . . detailed for a general court-martial
a. school or is a member of the bar of a federal court or of the highest court of a State . . . and
b. must be certified as competent to perform such duties by The Judge Advocate General of the armed force of which he is a member.”
2. SPCM & GCM. RCM 502(d). Defense counsel must be Article 27(b) certified.
3. Under RCM 502(d)(2), assistant trial counsel and assistant defense counsel need only
be commissioned officer.
4. Summary Court-Martial. Middendorf v. Henry, 425 U.S. 25 (1976). The Sixth
Amendment right to counsel does not extend to SCM.