> ## 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. # Junior Enlisted (E-1 to E-4) Charged Under Article 109 in the Army - URL: https://www.bodiesburied.com/trends/army-article-109-junior-enlisted/ - Published: 2026-10-28T08:19:07.000Z - Updated: 2026-10-30T08:13:49.000Z - Description: Army records from 2021 through 2025 show 26 courts-martial charging junior enlisted soldiers (E-1 to E-4) with property damage under Article 109. Every one of them also charged another article, most often domestic violence. - Author: Jocelyn C. Stewart - Tags: Understanding Trends, Article 109, Army [Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 109](https://www.bodiesburied.com/trends/article-109-courts-martial/) › Junior Enlisted (E-1 to E-4) **Short answer:** Army records from 2021 through 2025 show 26 courts-martial charging junior enlisted soldiers (E-1 to E-4) with property damage under Article 109\. Every one of them also charged another article, most often domestic violence. Only 15% of these cases were contested, compared with 29% across all Army Article 109 cases. The median confinement was 8 months, compared with 6 months. Based on 26 cases · 2021–2025 · Army records · data updated October 24, 2026 ## Article 109 Was Always Charged With Other Articles No case in this group charged Article 109 alone: all 26 included at least one other article. Article 128b (domestic violence) appeared in 15, Article 128 (assault) in 13, Article 92 (orders violation) in 7, and Article 115 (communicating threats) and Article 90 (disobeying an officer) in 5 each. A court-martial sentence covers every charge in the case. The confinement and discharges below therefore describe cases in which property damage was usually charged with violence or threats. ## Guilty Pleas in Most Cases Of the 26 accused, 22 pleaded guilty and 4 pleaded not guilty to at least one charge. The contested share was 15%. Across all Army Article 109 cases, 29% were contested. A case counts as contested when the accused pleads not guilty to any charge. Army records also say whether a guilty plea came with a plea agreement, though not what the agreement said. Of the 22 guilty pleas, 20 are recorded with one, and 2 have no entry. All 26 cases ended in a conviction on at least one charge, including the 4 that were contested. ## Longer Median Confinement Confinement was part of 23 of the 26 sentences (88%). The median confinement was 8 months, longer than the 6 months for all Army Article 109 cases. A quarter of terms were 1.3 years or longer. The shares by sentence length were about the same as for all Army Article 109 cases. Terms of more than one year were part of 7 of 26 convictions (27%), compared with 28%. Terms under 6 months were 42% in both groups. Convictions with no confinement were 12% in both groups. These are adjudged sentences, as announced at trial, before any plea-agreement cap, clemency, or appeal. | Adjudged confinement | Convictions | Share here | Share, all Army Article 109 cases | | ------------------------------- | ----------- | ---------- | --------------------------------- | | No confinement | 3 | 12% | 12% | | Under 6 months | 11 | 42% | 42% | | 6 months to 1 year | 5 | 19% | 18% | | More than 1 year, under 5 years | 6 | 23% | 22% | | 5 years or more | 1 | 4% | 5% | ## Most Convicted Soldiers Received a Punitive Discharge Among the 26 soldiers convicted, 21 received a bad-conduct or dishonorable discharge (81%), higher than the 70% across all Army Article 109 cases. Of those, 4 were dishonorable discharges. Only a general court-martial can adjudge a dishonorable discharge. A soldier with no punitive discharge may still face administrative separation, which these records do not show. ## General and Special Courts-Martial General courts-martial heard 14 cases and special courts-martial 11, with the level missing for 1\. The general court-martial share of 56% is lower than the 66% across all Army Article 109 cases. At general courts-martial, the median confinement was 1.1 years, and 21% of cases were contested. At special courts-martial, the median was 3 months, and 9% were contested. A special court-martial cannot adjudge more than one year of confinement. ## Few Cases Went to a Panel A military judge alone decided guilt in 23 of the 26 cases (88%). Members decided only 3, all on enlisted panels. The accused usually decides whether a military judge alone or a panel hears the case, and most judge-alone cases are guilty pleas. This group had only 4 contested cases and only 3 panels. Since 2019, a special court-martial can also be tried by a military judge alone, capped at six months of confinement with no punitive discharge. ## Timing and Location The trials took place from February 2021 to December 2025\. There were 9 in 2021 and 9 in 2022, then 5 in 2023, 1 in 2024, and 2 in 2025\. Army records in this data are sparse before 2021, after the services were required to begin publishing trial records under Article 140a by December 2020. Vilseck (Europe) tried 5 of the cases, Joint Base Lewis-McChord 4, Fort Campbell and Fort Bragg 3 each, and Fort Bliss 2\. Those five posts accounted for 65% of these cases. With so few cases, a few cases at one post can change that share. Larger posts try more cases of every kind. Junior enlisted soldiers made up 62% of all Army Article 109 cases. ## Gaps in the Records Since December 28, 2023, special trial counsel decide whether to prosecute covered offenses such as domestic violence. That rule depends on offense dates, which the records do not give. The records also do not include what property was damaged, its value, the evidence, plea terms, or any case handled by nonjudicial punishment or administrative separation. Dates and sources for the law changes mentioned here: [UCMJ change timeline](https://www.bodiesburied.com/trends/ucmj-change-timeline/). ### How We Counted Army courts-martial tried 2021–2025 that charged junior enlisted members (E-1 to E-4) under Article 109 (26 cases), compared with every Army Article 109 case. 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 109 (Property Other Than Military; Waste, Spoilage, Destruction): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-109-courts-martial/) (hub) - [Army Courts-Martial: Data and Trends](https://www.bodiesburied.com/trends/army-courts-martial/) (hub) - [Navy-Marine Corps Property Damage Cases Against Junior Enlisted (E-1 to E-4): Outcomes and Sentences](https://www.bodiesburied.com/trends/navy-marine-corps-article-109-junior-enlisted/) - [How Has Article 109 Changed in Army Courts-Martial Since 2021?](https://www.bodiesburied.com/trends/army-article-109-trend-2021-2025/) - [Air Force Article 109 Cases by the Numbers, 2016–2025](https://www.bodiesburied.com/trends/air-force-article-109-trend-2016-2025/) - [Army Article 93a Cases Against NCOs (E-5 to E-9): Outcomes and Sentences](https://www.bodiesburied.com/trends/army-article-93a-ncos/) - [Army Child Endangerment Cases Against Junior Enlisted (E-1 to E-4): Outcomes and Sentences](https://www.bodiesburied.com/trends/army-article-119b-junior-enlisted/) - [Army Child Sexual Abuse Cases Against Junior Enlisted (E-1 to E-4): Outcomes and Sentences](https://www.bodiesburied.com/trends/army-article-120b-junior-enlisted/) - [What Sentence Follows an Army Property Damage Conviction?](https://www.bodiesburied.com/trends/army-article-109-sent-2021-2025/) - [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.