Appeals court dismisses Bergdahl's challenge

A three-judge panel of the S. Court of Appeals for the District of Columbia Circuit on Tuesday ordered the dismissal of former Army soldier Bowe Bergdahl's claims in district court, ruling that a federal judge lacked the authority to overturn his military conviction. The decision reinstates Bergdahl's conviction for desertion and misbehavior before the enemy, charges to which he pleaded guilty in 2017.

The panel said District Judge Reggie Walton in Washington did not have the jurisdiction to vacate Bergdahl's court-martial conviction and sentence in 2023. Bergdahl had sued in civilian court in 2021, arguing that the military punishment violated his Fifth Amendment due-process rights. Walton had ruled that military judge Jeffrey Nance created a potential conflict of interest by failing to disclose his application for a position as an immigration judge in the Justice Department.

The appeals court concluded that only military tribunals have the authority to vacate a court-martial judgment. Circuit Judge Robert Wilkins wrote, "Because Bergdahl seeks to have his court-martial conviction declared expunged and without effect due to violations of the Constitution and military rules, and its consequences reversed, he effectively asked the District Court to vacate the military judgment." He added, "However, the authority to vacate a court-martial judgment belongs to tribunals exercising direct appellate review, not district courts conducting collateral review."

Chief Judge Sri Srinivasan and Circuit Judge Gregory Katsas also heard the appeal. Srinivasan and Wilkins were nominated by Democratic President Barack Obama, while Katsas was nominated by Republican President Donald Trump.

Eugene Fidell, one of Bergdahl's lawyers, did not immediately respond to an email seeking comment on Wednesday.

Background: Capture, plea, and conviction

Bergdahl, then a 23-year-old soldier from Hailey, Idaho, was stationed near Afghanistan's Paktika Province in June 2009 when he left his post without permission to hike to headquarters to complain about what he viewed as poor leadership in his unit. He was captured by forces from the Taliban-affiliated Haqqani network and repeatedly tortured before his release from captivity in 2014 as part of a prisoner swap that was sharply criticized by then-presidential candidate Donald Trump and others. The deal freed five Taliban prisoners from the Guantanamo Bay detention facility.

Several S. service members were wounded during the search for Bergdahl after his capture. He was charged with desertion and misbehavior before the enemy, and pleaded guilty to both charges in 2017, receiving a dishonorable discharge. Prosecutors at his court-martial had sought 14 years in prison.

During his 2015 campaign, Trump called for the death penalty for Bergdahl. The appeals court's ruling means Bergdahl's conviction stands, as only military courts have the power to overturn it.