Army Courts-Martial With Article 134 and Article 90, 2021–2026
In 43 Army courts-martial from 2021 to 2026, the general article, Article 134, was charged along with disobeying a superior commissioned officer under Article 90.
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Trends › By Offense › Article 134 › Army, with Article 90
Short answer: In 43 Army courts-martial from 2021 to 2026, the general article, Article 134, was charged along with disobeying a superior commissioned officer under Article 90. Confinement was part of 95% of the 40 sentences, with a median of 11 months, compared with 1 year in all Army Article 134 cases. Sentences of more than one year came in 45% of convictions, about the same as the 43% in the wider group.
Confinement Followed Almost Every Conviction
40 cases ended in a conviction on at least one charge, and 38 of those sentences included confinement (95%). Only 2 convictions (5%) had none, compared with 12% in all Army Article 134 cases from 2021 to 2026.
The median term was 11 months, a little shorter than the 1 year median in the wider group. A quarter of the terms were 3 years or longer. Each is an adjudged sentence, set at trial before any plea-agreement cap, clemency, or appeal, and covering every charge in the case.
General and Special Courts-Martial Compared
General courts-martial heard 31 of the 43 cases, and special courts-martial heard 12. The general share, 72%, is lower than the 84% in all Army Article 134 cases.
At the general level, 93% of convictions brought confinement, with a median of 1.7 years. At the special level, 100% did, with a median of 4 months. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge.
Sentence Bands
18 of the 40 convictions (45%) carried more than one year of confinement, compared with 43% in all Army Article 134 cases. Terms of 5 years or more made up 15%, compared with 10%. Terms of more than 1 year but under 5 years made up 30%, compared with 33%.
Terms of 6 months to 1 year made up 22%, compared with 20%, and terms under 6 months made up 28%, compared with 25%. Across most bands, this group was close to the wider group.
| Adjudged confinement | Convictions | Share here | Share, all Army Article 134 cases in 2021–2026 |
|---|---|---|---|
| No confinement | 2 | 5% | 12% |
| Under 6 months | 11 | 28% | 25% |
| 6 months to 1 year | 9 | 22% | 20% |
| More than 1 year, under 5 years | 12 | 30% | 33% |
| 5 years or more | 6 | 15% | 10% |
Pleas and Contested Results
29 accused pleaded guilty and 14 contested at least one charge. The contested share, 33%, is higher than the 23% for all Army Article 134 cases. 26 of the 29 guilty pleas are recorded with a plea agreement, and 3 have no entry.
Of 14 contested cases with a verdict, 3 ended in a full acquittal (21%), lower than the 25% in all Army Article 134 cases. 9 (64%) ended in a partial acquittal, meaning not guilty of at least one charge or specification but guilty of another. Army results list findings charge by charge.
Members Heard Most Contested Cases
Of the cases with the forum listed, 23% went to members: 9 enlisted panels and 1 officer panel. A military judge alone decided the other 33. Among the 14 contested cases, members heard 10 (71%).
The accused usually chooses the forum. Most guilty pleas go to a military judge alone, so the split mostly follows how many cases were contested.
Punitive Discharges
Of 35 convicted enlisted members, 29 received a punitive discharge: 15 bad-conduct and 14 dishonorable. In all Army Article 134 cases, 80% of convicted enlisted members received one.
5 convicted officers or warrant officers appear here, and 2 were dismissed. A sentence without a punitive discharge does not rule out an administrative separation later.
Rank and Other Charges
By rank, 24 accused were junior enlisted members (E-1 to E-4), 13 were NCOs (E-5 to E-9), and 6 were officers or warrant officers. The mix is similar to all Army Article 134 cases, where 54% were junior enlisted.
No case charged Article 134 alone. Besides Article 90, Article 128 (assault) appeared in 21 cases, Article 112a (drug) in 9, Article 115 (communicating threats) in 8, and Article 107 (false official statement) in 7. A case counts under each article it included.
Years and Installations
The cases were tried from February 2021 through May 2026: 14 in 2021, 10 in 2022, 10 in 2023, 6 in 2024, 2 in 2025, and 1 in 2026, a partial year.
Fort Bliss had 8 cases and Fort Hood had 6. Fort Bragg had 4, and Vilseck (Europe) and Fort Riley had 3 each. These five account for 56% of the 43 cases. Larger installations try more cases of every kind.
What the Records Do Not Include
The records hold trial dates, not offense dates. Both of the following rules turn on the offense date. Since December 28, 2023, special trial counsel 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 mix both kinds of cases.
The evidence, plea terms, nonjudicial punishment, and administrative separations are not in these records. 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. Dates and sources for the law changes: UCMJ change timeline.
How We Counted
Army courts-martial with trial dates in 2021–2026 that charged both Article 134 and Article 90 (43 cases), compared with all 589 Army Article 134 cases in those years.
Source: public court-martial records (Article 140a, UCMJ) in Military Trial Results, data updated October 24, 2026. Definitions, sources, and known gaps: how this data was built. Errors: content@bodiesburied.com.
Related Analysis
- Article 134 (General Article): Court-Martial Data and Trends (hub)
- Article 90 (Willfully Disobeying Superior Officer): Court-Martial Data and Trends (hub)
- Army Courts-Martial: Data and Trends (hub)
- Army Cases Charging Both Article 134 and Article 80
- Army Cases Charging Both Article 134 and Article 82
- Army Cases Charging Both Article 134 and Article 92
- Army Cases Charging Both Article 134 and Article 93
- Article 134 With Article 93a in the Army: What the Records Show
- Article 134 With Article 90 in the Navy and Marine Corps: What the Records Show
- Article 134 With Article 92 in the Navy and Marine Corps: What the Records Show
- Article 134 explained on the law firm's website
- Search every case in 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. This analysis is for education and information only. It is not legal advice, and every case is different.