Adrienne L. Clark v. United States
FourthAmendment CriminalProcedure JusticiabilityDoctri
Whether a military appellate court's decision to partially set aside findings of guilty and reassess a sentence comports with due process and the Uniform Code of Military Justice
No question identified. : IN THE Supreme Court of the Anited States ADRIENNE L. CLARK, Applicant, UNITED STATES OF AMERICA, Respondent. Application to the Hon. John G. Roberts, Jr. for Extension of Time to File a Petition for a Writ of Certiorari to the United States Court of Appeals for the Armed Forces Pursuant to Supreme Court Rules 13(5), 22, and 30, the Applicant, Adrienne L. Clark, requests a 60-day extension of time, to and including February 19, 2025, to file a Petition for a Writ of Certiorari. Unless an extension is granted, the deadline for filing the Petition will be December 21, 2025. This Application is being filed more than 10 days before that date. In support of this application, Applicant states the following: 1. The Court of Appeals for the Armed Forces (CAAF) declined the Applicant’s petition for a grant of review. This Court has jurisdiction under 28 U.S.C. § 1259(3). A copy of the CAAF’s denial order is attached to this application. 2. Applicant, a member of the United States Air Force, was tried by a general court-martial composed of officer members. Contrary to her pleas, she was convicted of one specification of sexual abuse of a child, in violation of 10 U.S.C. § 920b, and one specification each of extramarital sexual conduct, indecent language, indecent conduct, unenumerated conduct, possession of child pornography, and distribution of child pornography, in violation of 10 U.S.C. § 934. The Air Force Court of Criminal Appeals (AFCCA) reviewed Applicant’s case and set aside the findings of guilty for the extramarital sexual conduct and the unenumerated conduct. United States v. Clark , No. 40540, 2025 CCA LEXIS 208, at *3 (A.F. Ct. Crim. App. May 13, 2025). The AFCCA then affirmed the remaining findings of guilty and reassessed Applicant’s sentence. Id. 3. Applicant petitioned the CAAF to review the AFCCA’s decision. On September 22, 2025, the CAAF denied Applicant’s petition for review. 4. Applicant’s latest Air Force Appellate Defense Counsel, Major Megan Crouch, is Applicant’s military counsel for the purposes of her Petition for a Writ of Certiorari, but she is also detailed to 20 other cases, including three cases that will also be filing a petition for a writ of certiorari before this Court. Since the CAAF’s denial order, counsel’s statutory obligations in representing other clients required her to complete briefing in a variety of other cases before the AFCCA and the CAAF. 5. Additionally, the Air Force Appellate Defense Division currently does not have paralegal support to assist with formatting petitions for this Court or filings before any other court. Applicant’s appellate defense counsel will be responsible for formatting the lower courts’ decisions for this petition and the other petitions to be filed before this Court. The reduction of paralegal support has severely hampered the Division’s ability to prepare petitions before this Court. 6. Further, the printing process required for Applicant’s petition must be processed through a federal government agency (the Air Force), which has payment and processing requirements a private firm does not. The procurement process for a printing job cannot be forecasted with certainty, often has delays, and cuts approximately two weeks out of undersigned counsel’s time to finalize the petition for a writ of certiorari. The federal agency budgetary limitations are adding to the normal delays and constraints associated with processing printing through the Air Force. 7. Applicant thus requests a 60-day extension for counsel to prepare a petition that fully addresses the issues raised by the decision below and frames those issues in a manner that will be most helpful to the Court. For the foregoing reasons, Applicant respectfully requests that an order be entered extending the time to file a petition for a writ of certiorari up to, and including, February 19, 2025. November 6, 2025 Respectfully submitted, Mey GaP Megan R. Crouch, Maj, U.S. Air Force Cou