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# Who Prosecuted Contested Army Article 90 Cases? Trial Counsel Experience, 2023–2026
- URL: https://www.bodiesburied.com/trends/army-article-90-trial-counsel-experience-2023-2026/
- Published: 2026-10-30T05:28:56.000Z
- Updated: 2026-10-30T08:18:32.000Z
- Description: All 22 contested Army courts-martial charging Article 90 (disobeying an officer) from 2023 to June 2026 list a trial counsel of record, and 21 of them list exactly 2. The median prior-case count of the most experienced prosecutor on each team was 10.5.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Army, Article 90

[Trends](https://www.bodiesburied.com/trends/) › [Counsel Experience](https://www.bodiesburied.com/trends/counsel-experience/) › Article 90, trial counsel

**Short answer:** All 22 contested Army courts-martial charging Article 90 (disobeying an officer) from 2023 to June 2026 list a trial counsel of record, and 21 of them list exactly 2\. The median prior-case count of the most experienced prosecutor on each team was 10.5\. Full acquittals were 23% (5 of 22), lower than the 40% rate across contested Army cases.

Based on 22 cases · 2023–2026 · Army records · data updated October 24, 2026

## Two Prosecutors Was the Rule

Prosecution teams in these cases were almost all the same size. Of the 22 cases, 21 listed 2 trial counsel of record and 1 listed a single trial counsel. None listed 3 or more.

Lawyers appear for both sides in all 22 cases. Comparing the most experienced counsel of record on each side, the trial counsel had more prior cases in 11 cases (50%) and fewer in 11 cases (50%).

## How This Page Measures Experience

The only measure used is a count: the number of courts-martial a lawyer had already been counsel of record on in this data, on either side, in the Army, before the trial date. This count is not a measure of skill. Cases a lawyer tried before the records start are not included.

The records do not say which trial counsel led a case. Each case is therefore grouped by the trial counsel of record with the most prior cases. The page does not rate or rank lawyers.

## Prior Cases on the Prosecution Side

The median for the most experienced trial counsel was 10.5 prior cases. The 10 to 19 group was the largest, with 10 cases (45%).

Of the rest, 6 cases (27%) were in the 1 to 4 group, 3 cases (14%) in the 5 to 9 group, and 2 cases (9%) in the 20 or more group. In 1 case (5%), no trial counsel of record on the team had a prior case in this data.

| Prior cases (most experienced trial counsel) | Cases | Share |
| -------------------------------------------- | ----- | ----- |
| No prior cases                               | 1     | 5%    |
| 1 to 4                                       | 6     | 27%   |
| 5 to 9                                       | 3     | 14%   |
| 10 to 19                                     | 10    | 45%   |
| 20 or more                                   | 2     | 9%    |

## Verdicts Grouped by Prosecution Experience

The table lists full and partial acquittals for the 22 contested cases that reached a verdict, grouped by the most experienced trial counsel of record. A full acquittal is not guilty on every charge. A partial acquittal is not guilty on at least one charge or specification, with a guilty finding on another.

In the 10 to 19 group, 20% of cases ended in a full acquittal and 70% in a partial acquittal. All 6 cases in the 1 to 4 group ended in a partial acquittal, and none in a full acquittal. The 5 to 9 group had 2 of 3 full acquittals. Neither case in the 20 or more group ended in any acquittal, and the 1 case with no prior-case trial counsel ended in a full acquittal.

Most of these groups hold only a few cases, so one verdict moves the result. The records do not show the evidence, plea offers, or who did the work. The table describes verdicts, not the effect of a lawyer's experience.

| Prior cases (most experienced trial counsel) | Contested cases | Full acquittal | Partial acquittal |
| -------------------------------------------- | --------------- | -------------- | ----------------- |
| No prior cases                               | 1               | 1 of 1         | 0 of 1            |
| 1 to 4                                       | 6               | 0 of 6         | 6 of 6            |
| 5 to 9                                       | 3               | 2 of 3         | 1 of 3            |
| 10 to 19                                     | 10              | 20%            | 70%               |
| 20 or more                                   | 2               | 0 of 2         | 0 of 2            |

## Acquittal and Sentence Figures for Article 90

A contested case is one where the accused pleads not guilty to at least one charge. Of the 22 contested Article 90 cases, 5 ended in a full acquittal (23%). Across all contested Army cases tried in the same years, the rate was 40%.

Median confinement after a conviction was 2.5 years, compared with 1.5 years for contested Army cases overall. Sentences are as adjudged at trial, before any plea-agreement cap, clemency, or appeal.

## When the Cases Were Tried

The cases ran from January 2023 through June 2026\. There were 12 in 2023, 5 in 2024, 2 in 2025, and 3 in 2026, which is a partial year.

## New Rules During These Years

On December 28, 2023, the decision whether to prosecute covered offenses, including sexual assault, domestic violence, and murder, moved from commanders to special trial counsel. Separately, the military judge sets the sentence under new sentencing parameters when every guilty finding is for an offense after December 27, 2023\. Which rules applied depends on the offense date. These records list only trial dates, so the trials from 2024 on combine old-rule and new-rule cases.

## Limits of the Records

Army counsel names are nearly complete from 2021\. The page starts in 2023 so most lawyers have prior cases in the data. Name variants are merged as on Learn Your Lawyer. Navy and Marine Corps records name counsel only from mid-2025, mostly by surname, so they are not part of this page.

The records show charges, pleas, findings, and sentences. They do not show the evidence, the plea terms, or conduct that was handled outside a court-martial.

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 with trial dates in 2023–2026 that charged Article 90 and had a not-guilty or mixed plea (22 cases). Counsel of record are as listed in the public records.

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

- [Counsel Experience](https://www.bodiesburied.com/trends/counsel-experience/) (hub)
- [Article 90 (Willfully Disobeying Superior Officer): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-90-courts-martial/) (hub)
- [Who Defended Contested Army Article 90 Cases? Defense Counsel Experience, 2023–2026](https://www.bodiesburied.com/trends/army-article-90-defense-counsel-experience-2023-2026/)
- [Army Defense Counsel in Contested Article 107 Cases: Prior Cases and Verdicts, 2023–2026](https://www.bodiesburied.com/trends/army-article-107-defense-counsel-experience-2023-2026/)
- [Army Defense Counsel in Contested Article 112a Cases: Prior Cases and Verdicts, 2023–2026](https://www.bodiesburied.com/trends/army-article-112a-defense-counsel-experience-2023-2026/)
- [Army Defense Counsel in Contested Article 115 Cases: Prior Cases and Verdicts, 2023–2026](https://www.bodiesburied.com/trends/army-article-115-defense-counsel-experience-2023-2026/)
- [Army Defense Counsel in Contested Article 120 Cases: Prior Cases and Verdicts, 2023–2026](https://www.bodiesburied.com/trends/army-article-120-defense-counsel-experience-2023-2026/)
- [Army Defense Counsel in Contested Article 121 Cases: Prior Cases and Verdicts, 2023–2026](https://www.bodiesburied.com/trends/army-article-121-defense-counsel-experience-2023-2026/)
- [Army Defense Counsel in Contested Article 128 Cases: Prior Cases and Verdicts, 2023–2026](https://www.bodiesburied.com/trends/army-article-128-defense-counsel-experience-2023-2026/)
- [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.