United States v. Laminman

I agree that the decision of the Court of Military Appeals in United States v. Kossman, 38 M.J. 258 (CMA 1993), has reinstituted the “reasonable diligence” standard of United States v. Tibbs, 15 USCMA 350, 35 CMR 322, for purposes of testing compliance with the Article 10 UCMJ speedy trial requirement. However, I believe that Koss*527man also provides new guidance on the scope of criteria that should be considered in determining whether the “reasonable diligence” test has been satisfied and that these factors were not considered by the military judge in reaching her decision. Furthermore, the…