> ## Content Index > Fetch the complete content index at: https://www.bodiesburied.com/llms.txt > Use this file to discover other available public pages before exploring further. # How Has Article 87a Changed in Air Force Courts-Martial Since 2016? - URL: https://www.bodiesburied.com/trends/air-force-article-87a-trend-2016-2025/ - Published: 2026-10-30T08:04:14.000Z - Updated: 2026-10-30T08:04:14.000Z - Description: A military judge alone decided all 16 Air Force courts-martial from 2016–2025 that charged Article 87a (resisting apprehension, numbered since 2019). Most accused pleaded guilty: 20% of cases with a plea recorded were contested, compared with 48% across all Air Force cases in those years. - Author: Jocelyn C. Stewart - Tags: Understanding Trends, Article 87a, Air Force [Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 87a](https://www.bodiesburied.com/trends/article-87a-courts-martial/) › Air Force **Short answer:** A military judge alone decided all 16 Air Force courts-martial from 2016–2025 that charged Article 87a (resisting apprehension, numbered since 2019). Most accused pleaded guilty: 20% of cases with a plea recorded were contested, compared with 48% across all Air Force cases in those years. A punitive discharge followed 21% of enlisted convictions, compared with 56%. Based on 16 cases · 2016–2025 · Air Force records · data updated October 24, 2026 ## No Panels in Any Case The accused usually chooses whether a military judge alone or a panel of members decides guilt. In every one of these 16 cases, a military judge alone decided. No enlisted or officer panel heard a case. ## Guilty Pleas in 12 of 15 Recorded Cases The plea is listed in 15 of the 16 records. Of those, 12 accused pleaded guilty and 3 contested at least one charge. A contested case is one with a not-guilty or mixed plea. The contested share was 20%, lower than the 48% across all Air Force cases in those years. ## Always Charged With Something Else None of the 16 cases charged Article 87a by itself. Article 113 (misbehavior of a sentinel before 2019; drunken or reckless driving since) appeared in 9 cases. Article 86 (AWOL) appeared in 6\. Article 112a (drug) and Article 92 (orders violation) each appeared in 5, and Article 128 (assault) in 4. ## Fewer Punitive Discharges A punitive discharge followed 21% of enlisted convictions: 2 bad-conduct discharges and 1 dishonorable discharge. Across the whole Air Force, the share was 56%. The group also includes 2 convicted officers or warrant officers, and 1 of them was dismissed. A sentence without a punitive discharge does not rule out a later administrative separation. ## Confinement Of 16 convictions, 15 carried confinement. The median was 4 months, the same as in the rest of the Air Force. A quarter of the confinement sentences were 7 months or longer. These are adjudged sentences, before any plea-agreement cap, clemency, or appeal, and each covers every charge in the case. General courts-martial made up 25% of these cases (4 of 16). Special courts-martial heard the rest. A special court-martial caps confinement at one year. ## First Case in October 2019 The records hold no case from 2016 through 2018\. From October 2019 to September 2025, there were 16: 1 in 2019, 2 in 2020, 4 in 2021, 2 in 2022, 4 in 2023, 1 in 2024, and 2 in 2025\. They are 1% of the 2,795 Air Force courts-martial in those years. Air Force convictions that included Article 87a, by year: 2016 0, 2017 0, 2018 0, 2019 1, 2020 2, 2021 4, 2022 2, 2023 4, 2024 1, 2025 202016020170201812019220204202122022420231202422025 Air Force convictions that included Article 87a, by year ## A Larger Share of Convictions Among Air Force convictions with the offenses listed, Article 87a was part of 0 of 786 in 2016–2018 (0%) and 7 of 494 in 2023–2025 (1%), a larger share. The yearly count reached 4 in both 2021 and 2023. | Year | Convictions incl. Art. 87a | All convictions with offenses listed | Share | | ---- | -------------------------- | ------------------------------------ | ----- | | 2016 | 0 | 205 | 0% | | 2017 | 0 | 294 | 0% | | 2018 | 0 | 287 | 0% | | 2019 | 1 | 271 | 0% | | 2020 | 2 | 186 | 1% | | 2021 | 4 | 202 | 2% | | 2022 | 2 | 208 | 1% | | 2023 | 4 | 152 | 3% | | 2024 | 1 | 173 | 1% | | 2025 | 2 | 169 | 1% | ## Rank of the Accused The accused were 11 junior enlisted members (E-1 to E-4), 3 NCOs (E-5 to E-9), and 2 officers or warrant officers. In the rest of the Air Force, 62% were junior enlisted. ## Limits The records give trial dates, not offense dates, so they cannot show whether the 2019 or 2023 rule changes applied to a case. Air Force records never report plea agreements, and from 2016 to 2019 they rarely list a guilty plea. Nonjudicial punishment, administrative separations, and the evidence are not included. Dates and sources for the law changes mentioned here: [UCMJ change timeline](https://www.bodiesburied.com/trends/ucmj-change-timeline/). ### How We Counted Air Force courts-martial tried 2016–2025 that charged Article 87a (16 cases). The trend line uses convictions whose records list the offenses found, by trial year. Source: public court-martial records (Article 140a, UCMJ) in [Military Trial Results](https://www.bodiesburied.com/military-trial-results/), data updated October 24, 2026\. Definitions, sources, and known gaps: [how this data was built](https://www.bodiesburied.com/trends/how-the-military-trial-results-data-was-built/). Errors: content@bodiesburied.com. ## Related Analysis - [Article 87a (Resisting Apprehension, Numbered Since 2019): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-87a-courts-martial/) (hub) - [Air Force Courts-Martial: Data and Trends](https://www.bodiesburied.com/trends/air-force-courts-martial/) (hub) - [By Offense](https://www.bodiesburied.com/trends/by-offense/) (hub) - [Fewer or More? Resisting Apprehension Charges at Army Courts-Martial, 2021–2025](https://www.bodiesburied.com/trends/army-article-87a-trend-2021-2025/) (another service) - [Fewer or More? Resisting Apprehension Charges at Navy-Marine Corps Courts-Martial, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-87a-trend-2017-2025/) (another service) - [Air Force Article 109 Cases by the Numbers, 2016–2025](https://www.bodiesburied.com/trends/air-force-article-109-trend-2016-2025/) - [Air Force Article 113 Cases by the Numbers, 2021–2025](https://www.bodiesburied.com/trends/air-force-article-113-trend-2021-2025/) - [Air Force Article 115 Cases by the Numbers, 2021–2025](https://www.bodiesburied.com/trends/air-force-article-115-trend-2021-2025/) - [What Sentence Follows an Air Force Resisting Apprehension Conviction?](https://www.bodiesburied.com/trends/air-force-article-87a-sent-2016-2025/) - [Search every case in Military Trial Results](https://www.bodiesburied.com/military-trial-results/) (members) **About the author.** Jocelyn C. Stewart is a retired Army JAG with more than 24 years of trying courts-martial and more than 200 jury trials. She hosts *Where All The Bodies Are Buried* and runs the [Law Office of Jocelyn C. Stewart](https://www.ucmj-defender.com/?ref=bodiesburied.com). This analysis is for education and information only. It is not legal advice, and every case is different.