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# Army Article 115 Trials Before a Military Judge Alone: Verdicts and Sentences
- URL: https://www.bodiesburied.com/trends/army-article-115-contested-judge-alone-2021-2025/
- Published: 2026-10-30T08:16:53.000Z
- Updated: 2026-10-30T08:16:53.000Z
- Description: From 2021 to 2025, a military judge alone decided guilt in 17 contested Army cases that charged Article 115 (communicating threats). Only 2 of the 17 ended in a full acquittal (12%), compared with 24% across all contested Army Article 115 cases.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 115, Army

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 115](https://www.bodiesburied.com/trends/article-115-courts-martial/) › Decided by judge-alone

**Short answer:** From 2021 to 2025, a military judge alone decided guilt in 17 contested Army cases that charged Article 115 (communicating threats). Only 2 of the 17 ended in a full acquittal (12%), compared with 24% across all contested Army Article 115 cases. The median confinement was 7 months, compared with 6 months for all contested Army Article 115 cases.

Based on 17 cases · 2021–2025 · Army records · data updated October 24, 2026

## Partial Acquittals Were the Most Common Result

Of the 17 contested cases that reached a verdict, 12 ended in a partial acquittal. That means not guilty of at least one charge or specification, but guilty of another. Army records list findings charge by charge, so partial acquittals appear often.

Full acquittals, with a not guilty finding on every charge, came in 2 cases (12%). For all contested Army Article 115 cases, the full-acquittal rate was 24%.

The accused usually chooses whether a military judge alone or a panel of members decides guilt. Cases tried each way are not alike. These figures describe what happened, not what the forum caused.

## Other Articles in the Same Cases

Article 128 (assault) was charged with Article 115 in 12 cases. Article 134 (general article) appeared in 6\. Article 120 (sexual assault) and Article 128b (domestic violence) appeared in 5 each, and Article 90 (disobeying an officer) in 4.

## Confinement After Conviction

A conviction on at least one charge followed in 15 cases. Confinement was part of 14 of those sentences (93%).

The median confinement was 7 months, longer than the 6 months for all contested Army Article 115 cases. A quarter of the sentences with confinement were 1 year or longer. These are adjudged sentences, before any plea-agreement cap, clemency, or appeal, and each covers every charge in the case, including the other articles listed above.

## Discharges and Dismissals

A punitive discharge followed 55% of enlisted convictions: 2 bad-conduct discharges and 4 dishonorable discharges. For all contested Army Article 115 cases, the rate was 53%, about the same.

Of 4 convicted officers or warrant officers, 1 was dismissed. A dismissal is the officer equivalent of a punitive discharge. A sentence without one does not rule out a later administrative separation.

## A More Senior Group

The accused were 5 junior enlisted members, 7 NCOs, and 5 officers. The group is more senior than all contested Army Article 115 cases.

General courts-martial made up 15 of the 17 cases (88%), compared with 83% for all contested Army Article 115 cases. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge.

## Dates and Record Coverage

The records hold these cases from January 2021 through May 2025, with 4 cases in each year from 2021 to 2024 and 1 in 2025\. Army records in this data are sparse before 2021.

The records give trial dates, not offense dates, so they do not show which cases fell under the rules that took effect on December 28, 2023\. They also do not show the evidence, the plea terms, or cases resolved through nonjudicial punishment or administrative separation.

For what the offense covers and how it is defended, see [Article 115 on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-115/?ref=bodiesburied.com). Dates and sources for the law changes: [UCMJ change timeline](https://www.bodiesburied.com/trends/ucmj-change-timeline/).

### How We Counted

Army courts-martial with trial dates in 2021–2025 that charged Article 115, had a not-guilty or mixed plea and a result posted, and record a military judge alone as deciding guilt (17 cases), compared with all 46 such contested Army Article 115 cases. The accused usually chooses the forum, so the two groups are not alike.

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 115 (Malingering Before 2019, Communicating Threats Since): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-115-courts-martial/) (hub)
- [Army Courts-Martial: Data and Trends](https://www.bodiesburied.com/trends/army-courts-martial/) (hub)
- [Sentences](https://www.bodiesburied.com/trends/sentences/) (hub)
- [Contested Army Article 115 Cases Decided by Members (A Panel)](https://www.bodiesburied.com/trends/army-article-115-contested-members-2021-2025/)
- [Army Article 107 Trials Before Members (A Panel): Verdicts and Sentences](https://www.bodiesburied.com/trends/army-article-107-contested-members-2021-2025/)
- [Army Article 107 Trials Before a Military Judge Alone: Verdicts and Sentences](https://www.bodiesburied.com/trends/army-article-107-contested-judge-alone-2021-2025/)
- [Army Article 119b Trials Before Members (A Panel): Verdicts and Sentences](https://www.bodiesburied.com/trends/army-article-119b-contested-members-2021-2025/)
- [Army Article 128 Trials Before a Military Judge Alone: Verdicts and Sentences](https://www.bodiesburied.com/trends/army-article-128-contested-judge-alone-2021-2025/)
- [Army Article 80 Trials Before Members (A Panel): Verdicts and Sentences](https://www.bodiesburied.com/trends/army-article-80-contested-members-2021-2025/)
- [Army Article 80 Trials Before a Military Judge Alone: Verdicts and Sentences](https://www.bodiesburied.com/trends/army-article-80-contested-judge-alone-2021-2025/)
- [Article 115 explained on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-115/?ref=bodiesburied.com)
- [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.