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# General Article Plus Conspiracy: Courts-Martial Charging Articles 134 and 81
- URL: https://www.bodiesburied.com/trends/article-134-and-article-81-charged-together/
- Published: 2026-10-28T06:55:41.000Z
- Updated: 2026-10-28T08:19:52.000Z
- Description: Cases that charged the general article (Article 134) together with conspiracy (Article 81) were contested more often than general article cases overall.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 134, Article 81

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 134](https://www.bodiesburied.com/trends/article-134-courts-martial/) › With Article 81

**Short answer:** Cases that charged the general article (Article 134) together with conspiracy (Article 81) were contested more often than general article cases overall. Across 39 Army, Navy, and Marine Corps courts-martial from 2013–2026, 41% of cases with a recorded plea were contested, compared with 26% for all Article 134 cases. The median confinement was 2 years, compared with 1.3 years.

Based on 39 cases · 2013–2026 · Army, Navy, and Marine Corps records · data updated October 24, 2026

## A Higher Share of Contested Cases

The plea is recorded for 29 of the 39 cases. There were 17 guilty pleas and 12 contested pleas. A case is contested when the accused pleads not guilty to at least one charge. The contested share, 41%, is much higher than the 26% across all Army, Navy, and Marine Corps cases charging Article 134.

The plea is missing for many cases in this small group. So the contested share describes only the 29 cases with a recorded plea.

## Few Contested Cases Ended in a Full Acquittal

Of the 12 contested cases that reached a verdict, 8% ended in a full acquittal. That is lower than the 18% for all general article cases. Another 5 ended in a partial acquittal: a not-guilty finding on at least one charge or specification and a guilty finding on another.

Overall, 38 of 39 cases ended in a conviction on at least one charge. There are only 12 contested cases, so 1 verdict changes the full-acquittal rate by several points. The comparison shows a general direction only.

## Many Sentences Had No Confinement or Long Confinement

Confinement was part of 76% of the 38 convictions. The median confinement was 2 years, compared with 1.3 years for all Article 134 cases. A quarter of the terms were 4 years or longer. These are adjudged sentences: the sentences imposed at trial, before any plea-agreement cap, clemency, or appeal. Each covers every charge in the case.

Both ends of the range were more common here. No confinement was part of 9 convictions (24%), compared with 13% in the comparison group. Terms of 5 years or more followed 6 convictions (16%), compared with 13%. Terms under 6 months were less common: 4 convictions (11%), compared with 21%.

| Adjudged confinement            | Convictions | Share here | Share, all Army, Navy, and Marine Corps cases charging Article 134 |
| ------------------------------- | ----------- | ---------- | ------------------------------------------------------------------ |
| No confinement                  | 9           | 24%        | 13%                                                                |
| Under 6 months                  | 4           | 11%        | 21%                                                                |
| 6 months to 1 year              | 6           | 16%        | 18%                                                                |
| More than 1 year, under 5 years | 13          | 34%        | 35%                                                                |
| 5 years or more                 | 6           | 16%        | 13%                                                                |

## Terms Longer Than 1 Year at About the Usual Rate

Sentences of more than 1 year followed 19 of 38 convictions (50%), about the same as the 48% across all general article cases. Terms of more than 1 year but under 5 years followed 13 convictions (34%), about the same as the comparison figure of 35%.

General courts-martial heard 77% of these cases (30 of 39). Only a general court-martial can impose more than 1 year of confinement or a dishonorable discharge. A special court-martial is capped at 1 year.

## Punitive Discharges

A punitive discharge followed 76% of enlisted convictions: 13 bad-conduct discharges and 13 dishonorable discharges. The rate for all Article 134 cases in these services was 78%, about the same.

The records list 3 convicted officers or warrant officers, and 2 were dismissed. Dismissal is the officer equivalent of a punitive discharge. A sentence without a punitive discharge does not rule out a later administrative separation.

## Other Charges and Rank

The most common other charges were Article 92 (orders violation), in 12 cases, and Article 131b (obstruction, numbered since 2019), in 11\. Article 80 (attempt) was charged in 10 cases and Article 107 (false official statement) in 8.

Junior enlisted members (E-1 to E-4) made up 55% of the accused, NCOs 37%, and officers 8%. The junior enlisted share is the same as the 55% for all general article cases. So the longer median sentence here does not come with an unusual rank mix.

## Cases by Year and Installation

The 39 cases were tried from April 2013 to June 2026\. Most were tried in 2021, with 11 cases, and 2022, with 8\. No other year had more than 5, and the records show no cases in 2016\. The 2026 count covers only part of the year.

Camp Lejeune, North Carolina had 7 of these cases, Norfolk, Virginia had 6, and Joint Base Lewis-McChord had 5\. Okinawa, Japan had 3 and Bremerton, Washington had 2\. These five installations account for 59% of the 39 cases. Larger installations try more cases of every kind.

## Limits of the Records

Court-martial rules changed on January 1, 2019, under the Military Justice Act of 2016\. They changed again for covered offenses on December 28, 2023\. The records list trial dates, not offense dates, so they cannot sort these cases by which rules applied.

The records do not include nonjudicial punishment, administrative separations, or cases where no action was taken. They do not describe the evidence or the terms of any plea agreement.

For what the offense covers and how it is defended, see [Article 134 on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-134/?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, Navy, and Marine Corps courts-martial that charged both Article 134 and Article 81 (39 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](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 134 (General Article): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-134-courts-martial/) (hub)
- [Article 81 (Conspiracy): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-81-courts-martial/) (hub)
- [Articles 134 and 92 in the Same Case: What the Records Show](https://www.bodiesburied.com/trends/article-134-and-article-92-charged-together/)
- [General Article Plus Attempt: Courts-Martial Charging Articles 134 and 80](https://www.bodiesburied.com/trends/article-134-and-article-80-charged-together/)
- [General Article Plus Solicitation: Courts-Martial Charging Articles 134 and 82](https://www.bodiesburied.com/trends/article-134-and-article-82-charged-together/)
- [Fewer or More? General Article Charges at Army Courts-Martial, 2021–2025](https://www.bodiesburied.com/trends/army-article-134-trend-2021-2025/)
- [Air Force Article 134 Cases by the Numbers, 2016–2025](https://www.bodiesburied.com/trends/air-force-article-134-trend-2016-2025/)
- [Article 134 explained on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-134/?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.