A federal judge in Washington, D.C., has ruled against a former U.S. Army sergeant seeking to overturn his sexual assault conviction, deciding that military courts properly evaluated his constitutional arguments regarding restricted access to victim mental health records.
U.S. District Judge Amit P. Mehta granted summary judgment to the federal government on July 18, 2026, rejecting a lawsuit brought by former Sergeant Trevar D. Tinsley against the United States.
Tinsley filed the civil action seeking an expungement of his general court-martial conviction and sentence. He argued that his trial court violated his rights under the Confrontation Clause by refusing to review or disclose the mental health records of the victim, identified in court documents as A.B.
The dispute stems from an early 2018 incident following a meeting between Tinsley and A.B. through a dating app. According to court records, A.B. reported that Tinsley forced her into non-consensual sexual acts in a hotel room after she became intoxicated. A.B. subsequently underwent law enforcement interviews and disclosed during a second interview that she was receiving therapy for two psychological conditions and taking prescribed medications.
Prior to his military trial, Tinsley moved to compel production or conduct an in camera judicial review of A.B.’s mental health records, arguing the documents were necessary to test her credibility and establish a defense. The military judge denied the request, and a panel convicted Tinsley of one specification of sexual assault under Article 120 of the Uniform Code of Military Justice.
Tinsley appealed the conviction through military appellate channels, contending that the military judge’s decision deprived him of a fair trial.
Under Military Rule of Evidence 513, communications between psychotherapists and patients are privileged. While the rule previously allowed an exception when disclosure was constitutionally required, Congress removed that specific exception in 2014. To obtain an in camera review of privileged records under the current rule, a moving party must show a specific factual basis that records would yield admissible evidence, meet a specified statutory exception, avoid cumulative information, and show that reasonable efforts were made to obtain similar details elsewhere.
The Army Court of Criminal Appeals affirmed Tinsley’s conviction, finding that he failed to meet the procedural burdens required under Rule 513(e)(3) to demonstrate that the victim’s records contained admissible evidence. The Court of Appeals for the Armed Forces subsequently declined to review the case.
Tinsley then turned to federal district court for collateral review, asserting that the military courts failed to analyze whether withholding the records infringed upon his constitutional right to present a defense.
In his opinion, Judge Mehta wrote that the military court system gave Tinsley’s claims “full and fair consideration.”
“Plaintiff and the government briefed and argued this issue before the trial and appellate military courts, and the judges conducted hearings and issued reasoned decisions,” Mehta wrote. “Indeed, at every turn, the military courts squarely analyzed the issue of whether the Rule 513 privilege violated Plaintiff’s constitutional confrontation rights.”
The court noted that federal review of court-martial proceedings carries a deferential standard when military courts have thoroughly examined the issues raised.
“There are no grounds to disturb the military courts’ decisions that Plaintiff did not meet his burden to satisfy the requirements of Rule 513(e)(3) and was therefore not entitled to in camera review or production of A.B.’s mental health records,” Mehta wrote.
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