Service courts have two distinct responsibilities when reviewing allegations of post-trial and appellate delay.

militarylawyersYZ32832015First, service courts may grant relief to appellants for excessive post-trial delay under their broad authority to determine sentence appropriateness under Article 66(c), UCMJ. Second, as a matter of law, both the service courts and the CAAF may review claims of untimely review and appeal under the Due Process Clause of the Constitution using the principals announced in the case of United States v. Moreno , 63 M.J. 129 (C.A.A.F. 2006).