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# When A Military Judge Alone Decided a Contested Army Article 131b Case, 2021–2025
- URL: https://www.bodiesburied.com/trends/army-article-131b-contested-judge-alone-2021-2025/
- Published: 2026-10-30T05:27:15.000Z
- Updated: 2026-11-03T01:46:07.000Z
- Description: A military judge alone decided 21 contested Army cases charging Article 131b (obstruction) from 2021–2025. Only 1 of the 21 ended in a full acquittal, a 5% rate, lower than the 28% in all contested Army Article 131b cases.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 131b, Army

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 131b](https://www.bodiesburied.com/trends/article-131b-courts-martial/) › Decided by judge-alone

**Short answer:** A military judge alone decided 21 contested Army cases charging Article 131b (obstruction) from 2021–2025\. Only 1 of the 21 ended in a full acquittal, a 5% rate, lower than the 28% in all contested Army Article 131b cases. Among 19 convicted enlisted members, 74% received a punitive discharge, compared with 57% in all contested Army Article 131b cases.

Based on 21 cases · 2021–2025 · Army records · data updated October 24, 2026

## Obstruction Was Always Charged With Something Else

Article 131b is the obstruction article. In every one of these 21 cases, it was charged together with at least one other article. Article 120 (sexual assault) appeared in 10 cases, Article 92 (orders violation) in 7, Article 128b (domestic violence) in 6, and Article 134 (the general article) and Article 128 (assault) in 4 each.

A court-martial gives one sentence for all the charges in a case. The sentences and discharges below therefore reflect the other charges as well as the obstruction charge.

## 1 Full Acquittal in 21 Cases

Every case was contested, meaning the accused pleaded not guilty to at least one charge, and there were no guilty pleas. 1 of the 21 contested cases that reached a verdict ended in a full acquittal (5%). In all contested Army Article 131b cases, the full-acquittal rate was 28%.

17 cases split the charges, with the accused found not guilty of at least one charge or specification and guilty of another. Army results list findings charge by charge, which is why these partial acquittals are common in Army records.

## Discharges More Common Than the Comparison Group

Among 19 enlisted members convicted, 14 received a bad-conduct or dishonorable discharge (74%). That is more often than in all contested Army Article 131b cases (57%). 7 of the 14 were dishonorable discharges.

1 convicted officer or warrant officer appears here, and that officer was not dismissed. A sentence without a punitive discharge does not rule out a later administrative separation.

## Confinement and Median Sentence

20 cases ended in a conviction, and 15 of those sentences carried confinement. The median confinement was 2 years, close to the 2.1-year median in all contested Army Article 131b cases. A quarter of those sentences were 3.8 years or longer.

The figures are adjudged sentences, as announced at trial and before any plea-agreement cap, clemency, or appeal.

## Sentence Bands

9 of 20 convictions (45%) included more than one year of confinement, the same share as in all contested Army Article 131b cases. Sentences of more than 1 year and under 5 years made up 35%, compared with 33%, and sentences of 5 years or more made up 10%, compared with 12%.

5 convictions carried no confinement (25%), compared with 33%. Another 5 carried under 6 months (25%), compared with 15%. With 20 convictions, a single case changes these shares noticeably.

Only a general court-martial can adjudge more than one year of confinement.

| Adjudged confinement            | Convictions | Share here | Share, all contested Army Article 131b cases |
| ------------------------------- | ----------- | ---------- | -------------------------------------------- |
| No confinement                  | 5           | 25%        | 33%                                          |
| Under 6 months                  | 5           | 25%        | 15%                                          |
| 6 months to 1 year              | 1           | 5%         | 6%                                           |
| More than 1 year, under 5 years | 7           | 35%        | 33%                                          |
| 5 years or more                 | 2           | 10%        | 12%                                          |

## Forum, Rank, and Court Level

All 21 cases were decided by a military judge alone. The accused usually chooses whether a military judge alone or a panel of members decides guilt, so cases tried each way are not alike. These figures describe what happened, not what the forum caused.

By rank, the accused were 12 NCOs, 8 junior enlisted members, and 1 officer. The group is more junior than all contested Army Article 131b cases. 19 of the 21 cases were general courts-martial (90%), compared with 91% in all contested Army Article 131b cases.

A general court-martial can impose any lawful sentence, including long confinement and a dishonorable discharge. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge, so only the general courts-martial here could produce the longer sentences.

## When and Where

The cases were tried between January 2021 and April 2025: 5 in 2021, 5 in 2022, 3 in 2023, 7 in 2024, and 1 in 2025\. Fort Bragg had 3 cases. Fort Carson, Fort Benning, Fort Hood, and Fort Leavenworth had 2 each. Those five installations account for 52% of the 21 cases.

Larger installations try more cases of every kind. These small counts are not a measure of obstruction at any base.

## Rules in Effect and Gaps in the Data

Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute covered offenses such as sexual assault and domestic violence, which appeared in many of these cases. For cases where every guilty finding is for an offense after December 27, 2023, the military judge sets the sentence within new sentencing parameters. Both depend on offense dates, which the records do not give.

These records cover courts-martial only. They do not include nonjudicial punishment or administrative separation, and they do not describe the evidence.

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 with trial dates in 2021–2025 that charged Article 131b, had a not-guilty or mixed plea and a result posted, and record a military judge alone as deciding guilt (21 cases), compared with all 46 such contested Army Article 131b 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 131b (Obstruction, Numbered Since 2019): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-131b-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 131b Cases Decided by Members (A Panel)](https://www.bodiesburied.com/trends/army-article-131b-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 115 Trials Before a Military Judge Alone: Verdicts and Sentences](https://www.bodiesburied.com/trends/army-article-115-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/)
- [Search every case in Military Trial Results](https://www.bodiesburied.com/military-trial-results/) (members)

**Compare: federal court.** [Obstruction of Justice: Federal Sentences vs. Army Courts-Martial](https://www.bodiesburied.com/trends/federal-obstruction-vs-army/)

**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.