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More Than Just Implied Bias . . . : The Year in Pleas and Pretrial Agreements, Article 32, and Voir Dire and Challenges

Introduction

The 2007 term for the United States Court of Appeals for the Armed Forces (CAAF) and the service courts of criminal appeals yielded a bumper crop of cases in the area of pretrial procedures. As has been a recent trend, the courts continued to handle a steady volume of cases ad dressing all aspects of the guilty plea.1 The CAAF decided two very significant cases this term involving guilty plea procedure-United States v. Tippit2 and United States v. Tate.3 In Tippit, the CAAF held that an Article 10, Uniform Code of Military Justice (UCMJ),4 violation not litigated at the trial level is waived for appellate review, answering a question left open since the 2005 Mizgala case.5 In ...

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