UK launches review into US military's jurisdiction over serious crimes on British soil

Britain's government has quietly allowed American military personnel accused of serious crimes on its soil to escape the British justice system, handing investigations over to US military prosecutors who operate under a different legal framework with weaker protections for victims. The discovery has triggered an urgent review involving multiple government departments and police chiefs, prompted by a series of cases uncovered by the Guardian in which British women were assaulted by US airmen stationed at RAF bases in Suffolk and Norfolk.

The most prominent case involves Sarah Steele, a British woman who was raped and strangled by Captain Jacob Wulfson, a US fighter pilot, in his apartment after they met on a dating app. Cambridgeshire police handed the investigation to US military police within days. Wulfson was tried in a court martial on a US airbase in Suffolk before an all-male jury of air force officers. He was convicted of strangling an intimate partner but acquitted of sexual assault. He received a six-month sentence, which he is serving at RAF Lakenheath. When Downing Street learned the case had bypassed British courts entirely, officials called it "very concerning."

Wulfson's case is not isolated. The Guardian has identified at least four other cases in which US air force personnel avoided UK prosecution despite committing alleged crimes while off duty on British soil. Hannes Marschalek exposed himself to a 16-year-old girl and four young women in Littleport, Cambridgeshire; he admitted indecent conduct after a plea bargain at court martial, though the conviction was later quashed on technical grounds. Tyrion Davis was accused of raping two British women in Suffolk; he was convicted of one count of sexual assault at court martial but acquitted of ten further counts. James Loubeau faced allegations of a "spree" of rapes and sexual assaults across East Anglia, including drugging women and breaking into their homes. He was acquitted at court martial on charges from just one of six women who accused him; he was later convicted in Miami after an FBI investigation. Suffolk police transferred the Loubeau case to military prosecutors just eleven days after two British women reported being drugged and raped.

The pattern reveals a systemic problem rooted in how British and American law treat these crimes differently. Under the Uniform Code of Military Justice, the US military's legal framework, rape carries a narrower definition than British law recognizes. Many cases that would constitute rape under UK law are instead charged as sexual assault in military courts. Victims in court martial proceedings receive fewer protections than they would in British courts. The legal authority governing US forces in Britain dates to the 1950s and permits the American military to prosecute personnel only for crimes committed while on duty or against other military members, their property, or dependants. In all other cases, British police have the first option to investigate. Yet in practice, US military authorities have pushed to take control of investigations over which they have no legal right, and British police have acquiesced.

Home Office and justice ministers have now met with Steele to discuss her case and what changes might be needed. A government spokesperson acknowledged her "incredible bravery" and committed to "identifying and learning any lessons" to ensure victims are "supported and treated with the seriousness, dignity and compassion they deserve." Officials are working with the National Police Chiefs' Council to review guidance and ensure cases are referred to the Crown Prosecution Service for advice before jurisdiction is transferred. The Foreign Office has said it is "engaging with the US on this matter" and has promised to press Washington for a full account of what happened in Wulfson's case.

Two police forces directly involved—Suffolk and Cambridgeshire—are conducting their own reviews. Cambridgeshire is examining cases going back to 2018 but has not yet determined how many there have been. Suffolk is reviewing the decision-making around transferring primacy to the US air force. Gavin Stephens, chair of the National Police Chiefs' Council, has written to all chief constables in England and Wales to clarify their legal obligations when investigating visiting US forces. A government source revealed that ministers were alarmed to discover that UK police forces may not be seeking Crown Prosecution Service advice before handing investigations to the US military.

The scale of the issue is substantial. More than 12,000 US military personnel are stationed across the UK at fifteen bases and facilities. The largest concentrations are at RAF Lakenheath and RAF Mildenhall in Suffolk, with significant numbers also living in Norfolk and Cambridgeshire. MPs from across the political spectrum have expressed concern. Nick Timothy, the Conservative justice spokesperson, said Wulfson "should have been fully investigated by the English police and prosecuted in our courts." Jess Brown-Fuller, the Liberal Democrats' justice spokesperson, stated: "The British public expect crimes committed in England to be prosecuted in the English courts under English law. That expectation should not change simply because the accused is a member of the foreign military." Justice Minister Sarah Sackman acknowledged the victims in parliament, saying "Our thoughts are with the victim, and with the other victims whose experiences have subsequently come to light." What emerges is a question about sovereignty and protection: whether Britain can ensure its own citizens receive justice when harmed by foreign military personnel on British territory.