> ## 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. # What Happens to Army Junior Enlisted (E-1 to E-4) Facing Resisting Apprehension Charges? - URL: https://www.bodiesburied.com/trends/army-article-87a-junior-enlisted/ - Published: 2026-10-30T08:13:52.000Z - Updated: 2026-10-30T08:13:52.000Z - Description: The Army tried 22 junior enlisted soldiers (E-1 to E-4) under Article 87a (resisting apprehension) from 2021–2025. 82% of those convicted received a punitive discharge, compared with 63% in all Army Article 87a cases, and the median confinement was 7 months, compared with 6 months. - Author: Jocelyn C. Stewart - Tags: Understanding Trends, Article 87a, Army [Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 87a](https://www.bodiesburied.com/trends/article-87a-courts-martial/) › Junior Enlisted (E-1 to E-4) **Short answer:** The Army tried 22 junior enlisted soldiers (E-1 to E-4) under Article 87a (resisting apprehension) from 2021–2025\. 82% of those convicted received a punitive discharge, compared with 63% in all Army Article 87a cases, and the median confinement was 7 months, compared with 6 months. Based on 22 cases · 2021–2025 · Army records · data updated October 24, 2026 ## Punitive Discharges All 22 cases ended in a conviction on at least one charge. 18 of the 22 soldiers received a bad-conduct or dishonorable discharge (82%), and 4 of those discharges were dishonorable. In all Army Article 87a cases the rate was 63%. A soldier sentenced without a punitive discharge can still face a later administrative separation. ## Sentence Lengths 20 of the 22 sentences included confinement (91%). The median was 7 months, longer than the 6 months in all Army Article 87a cases. A quarter of the sentences with confinement were 1.7 years or longer, and 1 was a life sentence. Sentences longer than one year were more common here: 5 of 22 convictions (23%), compared with 17% in all Army Article 87a cases. The table shows each confinement band. All figures are adjudged sentences for every charge in the case, before any plea-agreement cap, clemency, or appeal. | Adjudged confinement | Convictions | Share here | Share, all Army Article 87a cases | | ------------------------------- | ----------- | ---------- | --------------------------------- | | No confinement | 2 | 9% | 10% | | Under 6 months | 10 | 45% | 53% | | 6 months to 1 year | 5 | 23% | 20% | | More than 1 year, under 5 years | 3 | 14% | 10% | | 5 years or more | 2 | 9% | 7% | ## Assault and Disobedience Charges Article 87a was charged with at least one other article in 21 of the 22 cases. Article 128 (assault) appeared in 13 cases. Article 90 (disobeying an officer) appeared in 8 and Article 92 (orders violation) in 7\. Article 128b (domestic violence) and Article 134 (general article) each appeared in 4. ## Guilty Pleas 19 soldiers pleaded guilty and 3 contested at least one charge. The contested share of 14% is lower than the 23% in all Army Article 87a cases. 18 of the 19 guilty pleas are recorded with a plea agreement, and 1 has no entry. Army records show whether an agreement existed, not its terms. ## Court Level and Forum 15 of the 22 cases were general courts-martial (68%), and special courts-martial made up the rest. Only a general court-martial can adjudge more than one year of confinement. Members heard 9% of the cases with the forum listed: 2 enlisted panels and no officer panels. A military judge alone decided the other 20. ## Where and When Fort Bragg had 4 cases. Fort Bliss and Vilseck (Europe) had 3 each, and Fort Benning and Fort Irwin had 2 each. These five installations account for 64% of the 22 cases. Larger installations try more cases of every kind. 2021 had the most trials, with 10\. The other years had 3 in 2022, 2 in 2023, 5 in 2024, and 2 in 2025\. The trials ran from March 2021 to November 2025. ## Rank Junior enlisted soldiers were 71% of the accused in all Army Article 87a cases. This group is limited to them. ## Limits of the Records 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\. The records give trial dates only, so trials from 2024 on mix both sets of rules. The evidence and plea terms are not described. 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 87a (22 cases), compared with every Army Article 87a 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 87a (Resisting Apprehension, Numbered Since 2019): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-87a-courts-martial/) (hub) - [Army Courts-Martial: Data and Trends](https://www.bodiesburied.com/trends/army-courts-martial/) (hub) - [Navy-Marine Corps Resisting Apprehension Cases Against Junior Enlisted (E-1 to E-4): Outcomes and Sentences](https://www.bodiesburied.com/trends/navy-marine-corps-article-87a-junior-enlisted/) - [Fewer or More? Resisting Apprehension Charges at Army Courts-Martial, 2021–2025](https://www.bodiesburied.com/trends/army-article-87a-trend-2021-2025/) - [How Has Article 87a Changed in Air Force Courts-Martial Since 2016?](https://www.bodiesburied.com/trends/air-force-article-87a-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 Resisting Apprehension Conviction?](https://www.bodiesburied.com/trends/army-article-87a-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.