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# Army Cases Charging Both Article 134 and Article 82
- URL: https://www.bodiesburied.com/trends/army-article-134-and-article-82-charged-together/
- Published: 2026-10-30T05:28:08.000Z
- Updated: 2026-10-30T08:17:51.000Z
- Description: The Army records show 20 courts-martial from 2021 to 2026 that charged the general article, Article 134, together with solicitation under Article 82. All 20 ended in a conviction, and the median confinement was 2.9 years, compared with 1 year in all Army Article 134 cases.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 134, Article 82, Army

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 134](https://www.bodiesburied.com/trends/article-134-courts-martial/) › Army, with Article 82

**Short answer:** The Army records show 20 courts-martial from 2021 to 2026 that charged the general article, Article 134, together with solicitation under Article 82\. All 20 ended in a conviction, and the median confinement was 2.9 years, compared with 1 year in all Army Article 134 cases. 85% of convictions carried more than one year of confinement, compared with 43%.

Based on 20 cases · 2021–2026 · Army records · data updated October 24, 2026

## Long Confinement Terms

20 cases ended in a conviction on at least one charge, and 18 of those sentences included confinement (90%). The median term was 2.9 years. In all Army Article 134 cases from 2021 to 2026, the median was 1 year. A quarter of the terms here were 9 years or longer.

These numbers are adjudged sentences, the sentences given at trial. They come before any plea-agreement cap, clemency, or appeal. A sentence covers every charge in a case, so these terms reflect the full set of charges, not only solicitation.

## No Terms Under 6 Months

17 of the 20 convictions (85%) carried more than one year of confinement, compared with 43% in all Army Article 134 cases. Terms of more than 1 year but under 5 years made up 55%, compared with 33%. Terms of 5 years or more made up 30%, compared with 10%.

No conviction in this group carried a term under 6 months; in all Army Article 134 cases, 25% did. 1 conviction (5%) fell between 6 months and 1 year, compared with 20%. 2 convictions (10%) had no confinement, compared with 12%. More than one year of confinement can be adjudged only at a general court-martial.

| Adjudged confinement            | Convictions | Share here | Share, Army-wide Article 134 cases |
| ------------------------------- | ----------- | ---------- | ---------------------------------- |
| No confinement                  | 2           | 10%        | 12%                                |
| Under 6 months                  | 0           | 0%         | 25%                                |
| 6 months to 1 year              | 1           | 5%         | 20%                                |
| More than 1 year, under 5 years | 11          | 55%        | 33%                                |
| 5 years or more                 | 6           | 30%        | 10%                                |

## Punitive Discharges

A punitive discharge followed 94% of enlisted convictions here: 13 dishonorable discharges and 4 bad-conduct discharges. In all Army Article 134 cases, the share was 80%.

The 2 convicted officers or warrant officers in this group were both dismissed. A dismissal is the officer equivalent of a punitive discharge. For enlisted members, a sentence without a punitive discharge does not rule out a later administrative separation.

## Pleas

14 accused pleaded guilty and 6 contested at least one charge. A contested case is one with a not-guilty or mixed plea. The contested share, 30%, is higher than the 23% in all Army Article 134 cases.

13 of the 14 guilty pleas are recorded with a plea agreement, and 1 has no entry. Army records say whether there was an agreement, not what it said, so any cap on confinement in an agreement does not appear here.

## Members Heard 2 Cases

A military judge alone decided guilt in 18 of the 20 cases. Members heard 2, both officer panels, which is 10% of the cases with the forum listed. No enlisted panel heard a case.

The accused usually chooses whether a military judge alone or a panel of members decides guilt. Most judge-alone cases are guilty pleas, so the split mostly follows how many cases were contested.

## Charges Alongside Solicitation

Every case charged at least one other article besides Article 134\. Apart from Article 82, Article 120b (child sexual abuse) appeared in 7 cases, Article 80 (attempt) in 4, Article 128b (domestic violence) in 3, and Article 90 (disobeying an officer) in 2.

A case counts under each article it included, so the counts overlap. The records list charges and findings, not the conduct behind them.

## Rank of the Accused

By rank, 12 accused were junior enlisted members (E-1 to E-4), 6 were NCOs (E-5 to E-9), and 2 were officers or warrant officers. In all Army Article 134 cases, 54% of the accused were junior enlisted, so this group is more junior.

## Years and Installations

The 20 cases were tried from May 2021 through September 2026: 2 in 2021, 7 in 2022, 1 in 2023, 6 in 2024, 2 in 2025, and 2 in 2026, a partial year.

Fort Hood had 4 cases and Joint Base Lewis-McChord had 3\. Fort Wainwright and Wheeler Army Airfield had 2 each, and Kaiserslautern (Europe) had 1\. These five installations account for 60% of the cases. Larger installations try more cases of every kind.

## Limits of the Records

The records list trial dates, not offense dates. Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute covered offenses, and new sentencing parameters apply when every guilty finding is for an offense after December 27, 2023\. Trials from 2024 on can fall under either set of rules, and the records cannot tell which.

Cases handled by nonjudicial punishment, administrative separation, or no action are not here. The records do not describe the evidence or plea terms, and Army records in this data are sparse before 2021.

For what the offense covers and how it is defended, see [Article 134 on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-134/?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 2021–2026 that charged both Article 134 and Article 82 (20 cases), compared with all 589 Army Article 134 cases in those years.

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 134 (General Article): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-134-courts-martial/) (hub)
- [Article 82 (Soliciting): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-82-courts-martial/) (hub)
- [Army Courts-Martial: Data and Trends](https://www.bodiesburied.com/trends/army-courts-martial/) (hub)
- [Army Cases Charging Both Article 134 and Article 80](https://www.bodiesburied.com/trends/army-article-134-and-article-80-charged-together/)
- [Army Cases Charging Both Article 134 and Article 92](https://www.bodiesburied.com/trends/army-article-134-and-article-92-charged-together/)
- [Army Cases Charging Both Article 134 and Article 93](https://www.bodiesburied.com/trends/army-article-134-and-article-93-charged-together/)
- [Army Courts-Martial With Article 134 and Article 90, 2021–2026](https://www.bodiesburied.com/trends/army-article-134-and-article-90-charged-together/)
- [Article 134 With Article 93a in the Army: What the Records Show](https://www.bodiesburied.com/trends/army-article-134-and-article-93a-charged-together/)
- [Article 134 With Article 90 in the Navy and Marine Corps: What the Records Show](https://www.bodiesburied.com/trends/navy-marine-corps-article-134-and-article-90-charged-together/)
- [Article 134 With Article 92 in the Navy and Marine Corps: What the Records Show](https://www.bodiesburied.com/trends/navy-marine-corps-article-134-and-article-92-charged-together/)
- [Article 134 explained on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-134/?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.