Articles 114 and 134 in the Same Case: What the Records Show
From 2021–2026, 18 Army, Navy, and Marine Corps courts-martial charged both Article 114 (dueling before 2019; endangerment since) and Article 134 (general article).
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Trends › By Offense › Article 114 › With Article 134
Short answer: From 2021–2026, 18 Army, Navy, and Marine Corps courts-martial charged both Article 114 (dueling before 2019; endangerment since) and Article 134 (general article). 80% of convicted enlisted members received a punitive discharge, compared with 60% in all Army, Navy, and Marine Corps cases charging Article 114. 39% of cases were contested, compared with 33% for Article 114 cases overall.
Discharge Was the Usual Result for Enlisted Members
Among 15 enlisted members convicted, 12 received a bad-conduct or dishonorable discharge (80%). That is more often than the 60% for all Army, Navy, and Marine Corps cases charging Article 114. Of the 12, 2 were dishonorable discharges.
The group also includes 1 convicted officer or warrant officer, who was dismissed. Dismissal is the officer equivalent of a punitive discharge. Members who received no punitive discharge could still face a later administrative separation.
Sentences to Confinement
Of the 16 convictions, 94% included confinement. The median term was 7 months, compared with 6 months across all Army, Navy, and Marine Corps cases charging Article 114. Among the sentences that included confinement, a quarter were 1.5 years or longer.
The terms are as adjudged at trial, before any plea-agreement cap, clemency, or appeal, and each reflects every charge in its case.
Pleas
Of the 18 cases, 11 ended in a guilty plea and 7 were contested, through a not-guilty or mixed plea. The contested share was 39%, compared with 33% in all Army, Navy, and Marine Corps cases charging Article 114.
Other Articles in These Cases
No case charged Article 114 alone: 0 of the 18, compared with 9 of 104 in all Army, Navy, and Marine Corps cases charging Article 114. Besides Article 134, which is in all 18, the most frequent charges were Article 92 (orders violation) in 7 cases, Article 128 (assault) in 6, Article 121 (larceny) in 5, and Article 113 (drunken or reckless driving) in 3.
Rank and Court Level
Junior enlisted members (E-1 to E-4) made up 61% of the accused, NCOs 28%, and officers 11%. Across all Army, Navy, and Marine Corps cases charging Article 114, junior enlisted members were 56%.
General courts-martial made up 61% of these cases (11 of 18), and special courts-martial made up the rest. Only a general court-martial can impose a dishonorable discharge or more than one year of confinement.
Trial Years and the Limits of the Records
The trials took place from April 2021 to March 2026: 2021: 5, 2022: 1, 2023: 4, 2024: 3, 2025: 4, and 2026: 1. The 2026 figure is for a partial year.
Beginning December 28, 2023, special trial counsel, not commanders, decide whether covered offenses such as sexual assault, domestic violence, and murder are prosecuted. Judges also sentence within new parameters when every guilty finding is for an offense after December 27, 2023. Because the records carry trial dates and not offense dates, the later trials cannot be split by which rules applied.
Cases closed through nonjudicial punishment, administrative separation, or no action are not part of these records. Evidence and plea terms are not described.
Dates and sources for the law changes mentioned here: UCMJ change timeline.
How We Counted
Army, Navy, and Marine Corps courts-martial that charged both Article 114 and Article 134 (18 cases). Air Force cases are left out because Air Force records rarely list the charges in acquittals.
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 114 (Dueling Before 2019, Endangerment Since): Court-Martial Data and Trends (hub)
- Article 134 (General Article): Court-Martial Data and Trends (hub)
- When Article 114 and Article 92 Are Charged Together, How Do Cases End?
- Articles 114 and 128 in the Same Case: What the Records Show
- Is Army Endangerment Prosecution Rising or Falling? Article 114, 2021–2025
- How Has Article 114 Changed in Air Force Courts-Martial Since 2021?
- AWOL Plus Disrespect: Courts-Martial Charging Articles 86 and 89
- 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.