When Sarah Steele woke up on the morning of 2 December 2023, she found herself in a pool of cold water in a bathtub. She was naked and in the apartment of an American fighter pilot she had met in person for the first time the night before. She was confused. Her head hurt, and so did her neck.<\/p>\n
This was the account Steele, a British academic, provided to prosecutors. They later accused the pilot, Capt Jacob Wulfson, of drugging and strangling Steele in his apartment in the east of England, and penetrating her vagina with his penis without her consent.<\/p>\n
In the criminal justice system for England and Wales, Wulfson\u2019s trial would probably have been held at the city\u2019s crown court, and the alleged offence categorised as rape. A jury of ordinary citizens \u2013 men and women \u2013 would have heard the case. If found guilty, a judge would have decided the sentence.<\/p>\n
However, Wulfson\u2019s case was tried at a court martial on a US airbase, despite his alleged crime taking place while he was off duty and in an English city. The proceedings followed US military<\/a> law, and the offence was not charged as rape but as sexual assault and \u201caggravated sexual contact\u201d.<\/p>\n Sarah Steele. Photograph: Antonio Olmos\/The Guardian<\/p>\n The judge, an air force colonel, sat before an American flag. He presided over a room of people in navy-blue uniforms. The jury \u2013 who heard the case in April this year at RAF Lakenheath, the largest US base in Britain \u2013 was a panel of eight air force officers.<\/p>\n All were stationed on the same base as Wulfson. All were men.<\/p>\n The panel\u2019s president, equivalent to a jury foreman, was the chief of the squadron that maintains the jets flown by Wulfson. Another panel member had been acquitted of sexual offences at a court martial several years earlier.<\/p>\n Apart from two Guardian reporters and the British witnesses who took the stand, everyone in the courtroom was American. At one point, the NHS was misnamed. At another, there was confusion about how long it would take to get to Wales.<\/p>\n Unlike in the British courts, there was no dock for the accused. Wulfson sat at a table with the defence team, directly across from the airmen selected to weigh the evidence in the week-long court martial.<\/p>\n Wulfson, a decorated aviator, flew F-35s, the US military\u2019s most advanced fighter jet. He served in Afghanistan and more recently had trained to fly carrying nuclear weapons. His elite squadron was nicknamed the \u201cValkyries\u201d.<\/p>\n He did not give evidence in the court martial. For much of the proceedings, he was silent, exercising his right under the US constitution not to testify. As a result, he did not provide his own account of what had happened in his apartment.<\/p>\n Wulfson (centre) with colleagues at the Dubai airshow in UAE in 2019. Photograph: Tech Sgt Joseph Pick\/US Air Forces Central<\/p>\n Instead, Wulfson\u2019s defence team sought to undermine Steele\u2019s credibility. His lawyer, an ex-army litigator who had flown in from Florida, depicted her as a financially motivated, sex-obsessed \u201cliar\u201d, subjecting her to the kind of theatrical and combative questioning more commonly found in US courtrooms.<\/p>\n Steele\u2019s experience throws into sharp relief what can happen when the alleged perpetrator of a crime in the UK is a member of the US military.<\/p>\n Technically, the UK authorities should have primary jurisdiction to prosecute crimes allegedly perpetrated by US service members off duty and off base. But the Wulfson case is one of several uncovered by the Guardian in which UK police and prosecutors appear to be ceding responsibility to their American military counterparts.<\/p>\n \u201cThe British authorities should be fighting to maintain jurisdiction,\u201d said Rachel VanLandingham, a law professor and former US air force judge advocate involved in efforts to reform military law. \u201cWhy should they trust the American military justice system with anything related to sexual assault?\u201d<\/p>\n In Wulfson\u2019s case, the jury found him guilty of strangling Steele, but not guilty of penetrating her vagina without her consent.<\/p>\n If his case had been heard in the English courts, the judge would have at this point taken responsibility for sentencing Wulfson. Under national guidelines, the equivalent offence of non-fatal strangulation carries a maximum sentence of five years.<\/p>\n At the court martial, Wulfson could choose between the judge or jury to decide his punishment. He opted to have his fellow airmen, with little or no legal experience, decide his sentence.<\/p>\n An F-35A Lightning II aircraft on the tarmac at RAF Lakenheath. Photograph: Alireza Boeini\/Alamy<\/p>\n The maximum sentence of imprisonment they could impose was 13 years. The prosecution requested five years. After three hours of deliberations, the men returned with a decision: Wulfson would be confined to a corrections facility for six months.<\/p>\n At the back of the courtroom, Steele looked exhausted. She had spent more than six hours on the stand that week. In a statement to the Guardian, she described the court martial as a \u201cdegrading\u201d process that had placed her, rather than Wulfson, on trial.<\/p>\n \u2018His hand was on my neck\u2019<\/p>\n RAF Lakenheath is in effect a small American town in west Suffolk<\/a>. There are more than 6,000 active-duty personnel plus their family members stationed at the base, where the convenience stores are stocked with American candy.<\/p>\n The base has its own shopping mall, a drive-thru Taco Bell and a miniature Statue of Liberty. The currency used in its shops and cafes is dollars. To reach the emergency services (it has its own hospital, police force and fire service) you dial 911.<\/p>\n RAF Lakenheath. Photograph: David Goddard\/Getty Images Photograph: Joshua Bright\/The Guardian<\/p>\n Lakenheath is home to the US air force\u2019s 48th fighter wing. A typical morning on base involves formations of fighter jets departing for training missions. Some of its jets were recently involved in the US bombardment of Iran.<\/p>\n Wulfson worked at the base\u2019s F-35 complex. After joining the Valkyries, one of Lakenheath\u2019s two F-35 squadrons \u2013 the second is known as the Grim Reapers \u2013 his name and callsign, Lone, could be seen printed on a flap of one of the jets capable of dropping thermonuclear bombs.<\/p>\n Wulfson met Steele on Tinder in September 2023. They both lived in Cambridge, a 40-minute drive from the airbase. \u201cI live on Midsummer Common,\u201d he wrote in one of his early messages. \u201cI\u2019m a pilot up at Lakenheath.\u201d<\/p>\n After exchanging messages on the dating app, they switched to WhatsApp, sharing details about their lives. Steele, then 39, had separated from her long-term partner earlier that year. In court, she said she had been dipping her toe back into the dating world. \u201cI was trying to see what was next in my life.\u201d<\/p>\n Weeks after they met online, Steele went into hospital for surgery to deal with complications arising from a mastectomy she had had several years earlier. From hospital, she texted with Wulfson, who was 29, as she lay recovering, joking about the strong painkillers she was taking.<\/p>\n The F-35 bearing Capt Jacob Wulfson\u2019s name taking off from Lakenheath base in 2024. Photograph: Benjamin Smith<\/p>\n They also exchanged messages sharing sexual fantasies. In conversations with friends, she referred to him as \u201cthe pilot\u201d.<\/p>\n By 1 December 2023, Steele was back on her feet and slowly returning to her fitness regime. At the gym that evening, she discussed with a friend whether she should meet Wulfson in person for the first time. He had texted her earlier that day to see what she was up to.<\/p>\n At 10.42pm, Wulfson wrote again: \u201cYou should come here.\u201d She asked where \u201chere\u201d was. \u201cAt my flat,\u201d he replied. Back at home, Steele quickly showered and ate some slices of apple before driving over to him.<\/p>\n Before arriving, she texted him with what she described as \u201ca few ground rules\u201d. It read: \u201cNo means no when said. No hands on my neck. Ever. Condoms please.\u201d She acknowledged that her message was \u201cblunt\u201d. Wulfson replied: \u201cYes, that\u2019s fair.\u201d<\/p>\n Security camera footage played in the court martial showed Steele arriving at his apartment building shortly after 11.30pm. Steele\u2019s account of what happened next was laid out by the military prosecutors.<\/p>\n Upstairs in the kitchen, Wulfson poured her a whisky and they chatted for around half an hour. The prosecution alleged it was while Steele was in his apartment that a potent drug, etizolam, entered her system. They advanced several theories about how it was administered but could not say for certain, and Wulfson was ultimately acquitted of the drug-related charge.<\/p>\n An American Boeing F-15E Strike Eagle fighter plane after landing at RAF Lakenheath on 7 April. Photograph: Leon Neal\/Getty ImagesThe perimeter fence of RAF Lakenheath keeps the public \u2013 and these protesters in April \u2013 at bay. Photograph: Joshua Bright\/The Guardian<\/p>\n From the kitchen, they moved to Wulfson\u2019s bedroom and undressed. Steele said on the witness stand that it was at this point \u201cthings sped up really quite fast\u201d. Asked by the prosecutor to describe what had happened, she said that once Wulfson was on top of her, he moved \u201cvery rapidly\u201d and penetrated her without a condom \u2013 against her stated wishes.<\/p>\n She said she tried to protest but couldn\u2019t. The prosecutor asked why not. \u201cHis hand was on my neck,\u201d she replied. She said she had wanted him to slow down but she \u201ccouldn\u2019t speak\u201d. She described looking up at him and noticing a light fixture on the ceiling above his head.<\/p>\n \u201cOne of his hands was on my arm, one of his hands was on my neck,\u201d Steele said. Asked how this felt, she said she was frightened, and that things then started going dark. \u201c[I felt] like I was going out, disappearing down a tunnel, and then nothing.\u201d<\/p>\n Prosecutors alleged that Steele had passed out in Wulfson\u2019s bed because of the etizolam in her body and the pressure he applied to her neck. \u201cAs he was squeezing her neck he was still penetrating her,\u201d alleged Christopher Mitchell, the air force major on the prosecution team.<\/p>\n Her next memory, Steele testified, was waking up in the cold water of Wulfson\u2019s bath.<\/p>\n She said her body was sore. Where, the prosecutor asked. \u201cThroat, neck, head, feet, genitals,\u201d she said. She described feeling confused about why she was in so much pain. At that point, she said, \u201cI was not sure of anything.\u201d<\/p>\n \u2018Like someone had beat the shit out of her\u2019<\/p>\n According to the prosecution\u2019s case, Wulfson eventually helped Steele out of the bath and returned her to his bed. She remained there until the afternoon, drifting in and out of sleep. The nausea was acute, she said. \u201cI had splitting pain in my foot and fire in my throat.\u201d<\/p>\n Later, after Wulfson had driven Steele home (she said she was unable to drive due to an injured foot), he sent her a series of texts. \u201cI am so sorry. I\u2019m horrified with myself,\u201d he wrote. \u201cI need to spend some time thinking about who I am,\u201d he added. \u201cI feel so badly about what happened.\u201d<\/p>\n Steele went that evening to A&E (a term that had to be explained to the American jury). She was scanned and X-rayed. A doctor who treated her testified that she had \u201cinjuries visible to the eye\u201d, namely bruising on her face and body. The doctor did not observe bruising on her neck, though she said Steele presented symptoms associated with strangulation.<\/p>\n Steele left hospital the following morning and a friend took her to a sexual assault referral centre. There, Steele said, she gave a urine sample and photos were taken of her vagina as part of an intimate examination conducted by a forensic nurse.<\/p>\n An F-35 taking off from RAF Lakenheath. Photograph: Nigel Blake\/Alamy<\/p>\n She also had an off-the-record conversation with a UK police officer stationed at the centre. Afterwards her friend, a woman who worked for the US air force, took Steele to a nearby US base to have a similar conversation with military police.<\/p>\n Within 24 hours, US air force police had arrested Wulfson. A spokesperson for the federal law enforcement agency told the Guardian it \u201cnegotiated jurisdiction\u201d with Cambridgeshire police and agreed the US \u201cwould take the lead\u201d. Cambridgeshire police confirmed it had agreed the Americans \u201cwould take investigative primacy\u201d.<\/p>\n Another friend who saw Steele around that time testified that \u201cit looked like someone had beat the shit out of her\u201d.<\/p>\n During the court martial, an alternative explanation for the injuries was presented by Wulfson\u2019s lawyer, Tim Bilecki, a prominent defence attorney in the US court martial system who posts videos on YouTube about his courtroom victories. Steele\u2019s injuries, he said, were the result of her own actions.<\/p>\n Tim Bilecki posts YouTube videos about his courtroom victories. Photograph: YouTube<\/p>\n Bilecki, an imposing presence with a blond crew cut and pinstripe suit, said Steele had started \u201cfreaking out\u201d in Wulfson\u2019s bed because of a traumatic assault earlier in her life. He claimed she had hit the pilot and head-butted him, leading her to sustain a head injury and a concussion.<\/p>\n The lawyer denied that Wulfson had assaulted Steele, strangled her or drugged her. \u201cCapt Wulfson has been falsely accused, plain and simple,\u201d he said, adding that the pilot was \u201cunequivocally not guilty\u201d.<\/p>\n At the core of Bilecki\u2019s case was an assault on Steele\u2019s credibility. The approach had various lines of attack, starting with a claim that Steele had fabricated the allegations as part of an elaborate scheme to extract money from a UK government compensation scheme for crime victims.<\/p>\n In his opening statement, Bilecki confidently asserted: \u201cThis is a play for money,\u201d saying his client had been \u201cset up for money\u201d. Steele repeatedly denied this. She said she had applied to the scheme \u2013 and had still not received a decision \u2013 to cover loss of wages arising from difficulties going back to work after the assault.<\/p>\n The prosecution described Bilecki\u2019s theory as absurd. By his closing submissions, he seemed less confident in this aspect of his case. \u201cDo I know if she\u2019s doing this for money? I don\u2019t know,\u201d he said.<\/p>\n Another line of attack was that Steele abused prescription drugs. At one point, Bilecki seized on the texts she had sent Wulfson from hospital while recovering from breast surgery. She had joked about being on strong American painkillers.<\/p>\n By attempting to present Steele as a drug abuser, which she strongly denied, he suggested she had in fact taken the etizolam, a benzodiazepine-like drug banned in the UK and sometimes called \u201cstreet Valium\u201d. Bilecki suggested she may have wanted to \u201cpop a few pills before going to meet a fighter pilot significantly younger than her\u201d.<\/p>\n Get in touch<\/p>\n Contact Harry Davies about this story<\/p>\n If you have something to share about this story, you can contact Harry using one of the following methods:<\/p>\n Secure Messaging in the Guardian app<\/p>\n The Guardian app has a tool to send tips about stories. Messages are end to end encrypted and concealed within the routine activity that every Guardian mobile app performs. 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