- a worthless check offense under Article 134, UCMJ, requires that the accused dishonorably fail to maintain funds after the check was made and uttered; the offense does not require an intent to defraud or knowledge by the accused that he has insufficient funds to cover the check; the offense can be satisfied with bad faith or gross indifference, which is a lesser mens rea than the specific intent to defraud required in Article 123a, UCMJ
- the gambler’s defense to worthless check offenses under Article 134, UCMJ, is overruled
CAAF Opinion Digest · III.A.68 · Crimes Pre-2019 offenses
Article 134 -- Check, Worthless, Making and Uttering -- by Dishonorably Failing to Maintain Funds
Offenses committed before 1 January 2019 (pre-2016 amendment) — opinions from the 1999 through 2020 Terms of Court.
1 digested opinion, 2008–2008 Terms
2008 (Transition Term)
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Last updated by the court: Oct 13, 2026 · mirrored Oct 29, 2026 · digest page IIIA68 · Always confirm a holding against the opinion itself (linked from each case name).