The D.C. Circuit ruled that a federal judge had exceeded his authority by tossing the court-martial of U.S. Army soldier Robert "Bowe" Bergdahl, who was dishonorably discharged for deserting his unit in Afghanistan in 2009. 

Bergdahl was accused of leaving his post without permission to report poor conditions and leadership deficiencies within his unit to headquarters, Courthouse News Service reported. He was captured by the Taliban-allied Haqqani network and held hostage for five years. He was freed when President Barack Obama approved a prisoner swap in 2018 for five Taliban members detained at Guantánamo Bay, Cuba.

The three-judge D.C. Circuit panel determined that U.S. District Judge Reggie Walton lacked the authority to grant Bergdahl's request to vacate the court-martial judgment because federal courts lack jurisdiction on collateral review under Article III of the Constitution.

U.S. Circuit Judge Robert Wilkins wrote in the ruling that the authority to review a court-martial judgment lies exclusively with military tribunals who have been empowered with direct appellate review. The case was remanded back to lower court.