Understanding the Mistake of Fact Defense in Military Sexual Assault Cases

Understanding the Mistake of Fact Defense in Military Sexual Assault Cases

Military sexual assault allegations are among the most serious accusations a service member can face. The consequences can be life-altering, affecting both personal and professional futures. Navigating these cases requires a deep understanding of military law and the defenses available under the Uniform Code of Military Justice (UCMJ). One of the critical and nuanced defenses in these cases is the mistake of fact defense regarding consent. In this blog, we explore what mistake of fact means in the military sexual assault context, how it is applied, and why it is a vital defense strategy.

What is the Mistake of Fact Defense?

The mistake of fact defense is a legal argument that the accused held a reasonable but mistaken belief that the other party consented to the sexual activity. This belief must stem from ignorance or misunderstanding of a material fact—in this case, consent.

According to military defense lawyer Michael Waddington, for this defense to be viable, the accused’s belief in consent must be reasonable under the circumstances. It cannot arise from recklessness or negligence. In other words, a service member cannot simply claim they thought there was consent without reasonable grounds to support that belief.

Key Elements of Mistake of Fact Defense

  • Incorrect Belief: The accused must have had an honest and mistaken belief that consent was given.
  • Reasonableness: This belief must be reasonable from the perspective of a person of average intelligence and awareness.
  • Non-Negligence: The belief cannot be based on reckless or negligent behavior in determining consent.

Applying Mistake of Fact in Military Sexual Assault Cases

The UCMJ provides the framework for prosecuting and defending sexual assault cases within the military. Courts martial consider the context of the relationship and interactions between the parties when evaluating the reasonableness of the accused’s belief in consent.

For example, if two service members have a history of consensual interactions or sexual behavior, and the accused reasonably believes the other party consented during the incident in question, then mistake of fact may be a strong defense. Conversely, if the accused had no prior relationship or any indication that consent existed, the defense is unlikely to succeed.

Example Scenario

Imagine a situation where two individuals have been dating or “talking,” as younger generations might say, and one initiates physical contact during a date. If the other party does not explicitly refuse or resist, and the accused reasonably interprets cues such as reciprocal touching, smiling, or flirting as consent, the accused may invoke mistake of fact if later accused of sexual assault.

Michael Waddington emphasizes the importance of the prosecution proving beyond a reasonable doubt not only that the sexual act occurred but also that the accused did not have a reasonable mistaken belief of consent. This dual burden makes mistake of fact a powerful defense when supported by credible evidence.

Limitations and Challenges of the Mistake of Fact Defense

Despite its potential, the mistake of fact defense faces significant challenges:

  • Subjectivity of Reasonableness: What constitutes a “reasonable” belief can vary widely depending on individual perceptions and circumstances, making it a complex issue for courts to adjudicate.
  • Communication and Consent: Misinterpretation of non-verbal cues or past interactions can complicate matters. Clear, affirmative consent is critical to avoiding such misunderstandings.
  • Strict Scrutiny: Military courts often scrutinize mistake of fact defenses closely due to the serious nature of sexual assault allegations and the military’s commitment to maintaining discipline and respect.

Important Considerations for Service Members

Given the gravity of sexual assault allegations, service members should proceed with caution in any intimate encounter. It is essential to obtain clear, affirmative consent to minimize the risk of misunderstandings that could lead to accusations.

If accused, it is crucial not to make hasty statements to investigators or law enforcement without legal counsel. As Michael Waddington advises, the truth is often the best defense, but it must be presented carefully with the guidance of an experienced military defense attorney specializing in sexual assault cases.

Why Seek Experienced Legal Counsel?

Military sexual assault defense requires specialized knowledge of the UCMJ and military court procedures. An attorney with years of experience can analyze the facts, identify viable defenses like mistake of fact, and develop a strategic response that protects the accused’s rights.

Conclusion

The mistake of fact defense in military sexual assault cases is a critical legal tool that hinges on the accused’s reasonable belief in consent. While it can offer a robust defense, it is not a catch-all solution and demands careful consideration of the circumstances and evidence. For service members facing such serious allegations, understanding this defense and seeking expert legal counsel promptly can make a significant difference in the outcome of their case.

For those navigating these complex issues, consulting with attorneys like Michael Waddington and Alexandra Gonzalez-Waddington, who specialize in military sexual assault defense, offers the best chance to build a strong defense and protect one’s future.

Remember, clear communication and respect for consent are not only moral imperatives but legal necessities in all interactions.

Additional Resources

Full Transcription

My name is Michael Waddington and I’m a military defense lawyer. In a military sexual assault case, there are multiple defenses that you can raise. One of the most important defenses in a military sexual assault case is mistake of fact. And that defense basically is this. If you engage in sexual behaviors or sexual relations with somebody and then they later turn and say that you sexually assaulted them or raped them or committed some sort of a sex crime against them, then the prosecution must prove beyond a reasonable doubt that you committed that offense, meaning they have to prove beyond a reasonable doubt each and every element of the sexual assault allegation. And the defense can raise through evidence. You can’t just make it up. There has to be evidence on the record in the trial of mistake of fact on behalf of the accused. What that means is from the perspective of the accused, the person engaging in the sexual relations, the government must prove not only they committed the crime, but they must prove beyond a reasonable doubt that that person that’s being accused did not have a mistaken belief that the person was consenting. But in order for someone to be held criminally liable for a military sexual assault, that person must know that they’re committing a crime. There has to be a reasonable mistake of fact based on the circumstances. So I’m going to explain what a reasonable mistake of fact to sexual assault would be. Let’s say I’m in college and I meet someone in the dorm and we go to lunch, we hang out. I think she likes me. She flirts with me. We watch movies in her bed late at night and we kiss a few times. And let’s say I then invite her to the movies and I take this woman on this date to the movies and we’re sitting there watching a romantic movie and she’s cuddling into me and I think everything’s great. And I put my hand on her leg and I start rubbing her leg and I start rubbing her inner thigh. She doesn’t say stop, doesn’t say no, doesn’t say anything. And I think that she’s reciprocating. She’s kind of, you know, smiling and making soft sounds like or whatever a person makes in that situation. But you get my point that if the person is seems to be reciprocating and not resisting and the person is consenting, then in the mind of the person that’s doing the touching, they are not committing a crime. And so let’s say two weeks later that the woman that was at the movie theater who had her leg and her thigh touched says, you know what, I was sexually assaulted at the movie theater. I didn’t verbally tell that man, the guy, that he could touch me. And let’s say the charge comes from that. And charges do come from this. We’ve done plenty of cases like this. When we get to court, we’re going to raise evidence on cross-examination and potentially through our client to show what the state of the mind of the accused was. So from the state of the mind of the accused, he’s thinking, I like her. She likes me. We text each other all the time. We hang out together. I think we are talking, as they say nowadays, which is equivalent to dating or seeing each other from those of us that are older than 40. But if you’re talking or seeing someone and you think that they are willing and wanting your sexual ad

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Understanding the Mistake of Fact Defense in Military Sexual Assault Cases

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