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# What Happens to Army Junior Enlisted (E-1 to E-4) Facing Disobeying An Officer Charges?
- URL: https://www.bodiesburied.com/trends/army-article-90-junior-enlisted/
- Published: 2026-10-28T08:18:59.000Z
- Updated: 2026-10-30T08:13:42.000Z
- Description: Junior enlisted members (E-1 to E-4) charged under Article 90, disobeying an officer, received longer sentences than the Army's Article 90 cases as a whole. Across 99 courts-martial from 2021–2025, the median confinement was 9 months, compared with 6 months.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 90, Army

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 90](https://www.bodiesburied.com/trends/article-90-courts-martial/) › Junior Enlisted (E-1 to E-4)

**Short answer:** Junior enlisted members (E-1 to E-4) charged under Article 90, disobeying an officer, received longer sentences than the Army's Article 90 cases as a whole. Across 99 courts-martial from 2021–2025, the median confinement was 9 months, compared with 6 months. Of 98 convicted members, 80 received a punitive discharge; across all Army Article 90 cases, the share was 72%.

Based on 99 cases · 2021–2025 · Army records · data updated October 24, 2026

## Longer Terms for the Most Junior Ranks

Of 98 convictions, 92% included confinement. Half of those terms were 9 months or less, and a quarter were 1.6 years or longer. Across all Army Article 90 cases, the median was 6 months.

Sentences longer than one year were adjudged in 35 of 98 convictions (36%), compared with 31% in the wider group. Only 8% had no confinement, compared with 10%. These are adjudged sentences, set at trial before any plea-agreement cap, clemency, or appeal. Each covers every charge in the case, not Article 90 alone.

| Adjudged confinement            | Convictions | Share here | Share, all Army Article 90 cases |
| ------------------------------- | ----------- | ---------- | -------------------------------- |
| No confinement                  | 8           | 8%         | 10%                              |
| Under 6 months                  | 32          | 33%        | 40%                              |
| 6 months to 1 year              | 23          | 23%        | 19%                              |
| More than 1 year, under 5 years | 30          | 31%        | 24%                              |
| 5 years or more                 | 5           | 5%         | 7%                               |

## Most Received a Punitive Discharge

For enlisted members, a punitive discharge is a bad-conduct discharge or a dishonorable discharge. Of 98 convicted junior enlisted members, 80 received one: 62 bad-conduct and 18 dishonorable. The share across all Army Article 90 cases was 72%.

A sentence without a punitive discharge does not rule out a later administrative separation. These court records do not track administrative separations.

## Disobedience Was Rarely the Only Charge

Of the 99 cases, 95 charged at least one more article. Article 128 (assault) appeared in 42 cases, Article 128b (domestic violence) in 33, Article 112a (drug) in 25, Article 134 (general article) in 23, and Article 120 (sexual assault) in 13.

A sentence covers the whole case, so the confinement and discharge figures include these other charges. The records cannot show how much of a sentence was for the disobedience charge.

## Most Cases Were General Courts-Martial

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 adjudge a dishonorable discharge. Of these cases, 75 were general courts-martial (77% of the cases with a court level listed), compared with 73% across all Army Article 90 cases. Another 22 were special courts-martial, and 2 have no court level listed.

The median confinement was 1 year at general courts-martial and 4 months at special courts-martial. The contested share was 19% at general courts-martial and 5% at special courts-martial.

## Most Cases Were Guilty Pleas

Of the 99 accused, 84 pleaded guilty and 15 contested at least one charge. The contested share was 15%, compared with 25% across all Army Article 90 cases. Of the 84 guilty pleas, 77 are recorded with a plea agreement and 7 have no entry. Army records show whether an agreement existed but not what it said.

Of the 15 decided contested cases, 7% ended in a full acquittal, lower than the 13% across all Army Article 90 cases. Another 12 were partial acquittals: not guilty of at least one charge or specification, but guilty of another. Army results list findings charge by charge, so partial acquittals are common.

## Who Decided Guilt

A military judge alone decided 90 cases, and an enlisted panel decided 8\. No case went to an officer panel. Members heard 8% of these cases, compared with 16% across all Army Article 90 cases. Among contested cases, members heard 7 of 14 (50%).

The accused usually chooses between a judge and a panel. Most judge-alone cases are guilty pleas, so the low panel share matches the low contested share.

## Junior Enlisted Members Only

All 99 accused in this group were junior enlisted members. Across all Army Article 90 cases, 64% of the accused were junior enlisted, so this group includes most of the Army's Article 90 cases.

## Cases by Year and Installation

The cases were tried from January 2021 to December 2025\. There were 25 in 2021, 23 in 2022, 18 in 2023, 18 in 2024, and 15 in 2025\. Army records in this data are sparse before 2021.

Fort Bliss had the most cases (13). Fort Campbell, Fort Bragg, and Joint Base Lewis-McChord had 10 each, and Fort Hood had 8\. Those five installations had 52% of the 99 cases. Larger installations try more cases of every kind, so a high count alone does not mean a base has a problem with this offense.

## What the Records Do Not Show

Since December 28, 2023, special trial counsel decide whether to prosecute covered offenses such as sexual assault and domestic violence. Judges sentence under new parameters when every guilty finding is for an offense after December 27, 2023\. The records give trial dates, not offense dates, so cases from 2024 on include cases under both sets of rules.

Disobedience handled through nonjudicial punishment or administrative separation is not included. The records do not show the evidence or the terms of any plea agreement.

For what the offense covers and how it is defended, see [Article 90 on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-90/?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 tried 2021–2025 that charged junior enlisted members (E-1 to E-4) under Article 90 (99 cases), compared with every Army Article 90 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 90 (Willfully Disobeying Superior Officer): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-90-courts-martial/) (hub)
- [Army Courts-Martial: Data and Trends](https://www.bodiesburied.com/trends/army-courts-martial/) (hub)
- [What Happens to Army NCOs (E-5 to E-9) Facing Disobeying An Officer Charges?](https://www.bodiesburied.com/trends/army-article-90-ncos/)
- [Junior Enlisted (E-1 to E-4) Charged Under Article 90 in the Air Force](https://www.bodiesburied.com/trends/air-force-article-90-junior-enlisted/)
- [What Happens to Navy-Marine Corps Junior Enlisted (E-1 to E-4) Facing Disobeying An Officer Charges?](https://www.bodiesburied.com/trends/navy-marine-corps-article-90-junior-enlisted/)
- [Is Army Disobeying An Officer Prosecution Rising or Falling? Article 90, 2021–2025](https://www.bodiesburied.com/trends/army-article-90-trend-2021-2025/)
- [Air Force Article 90 Cases by the Numbers, 2016–2025](https://www.bodiesburied.com/trends/air-force-article-90-trend-2016-2025/)
- [Article 90 explained on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-90/?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.