Guilty Pleas in False Claims Against the United States Cases: Federal Court vs. Courts-Martial
Of 16 courts-martial charging frauds against the United States with a plea recorded, 11 (69%) were guilty pleas. In federal court, 86% of people sentenced for cases with a conviction under 18 U.S.C. 287 (false claims) pleaded guilty, and 86% of defendants whose 287 cases ended did so. The court-mart
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In brief: Of 16 courts-martial charging frauds against the United States with a plea recorded, 11 (69%) were guilty pleas. In federal court, 86% of people sentenced for cases with a conviction under 18 U.S.C. 287 (false claims) pleaded guilty, and 86% of defendants whose 287 cases ended did so. The court-martial group is small, and the counts do not cover the same cases.
This post uses the U.S. Sentencing Commission's records of 437 people sentenced in federal court in fiscal years 2016 to 2025 and the Federal Judicial Center's records of 486 federal defendants whose cases ended in fiscal years 2016 to 2025, compared with court-martial results from this site's Military Trial Results data (updated November 2, 2026). It is part of the Federal Prosecution Analysis series, which builds on Military Moves Toward Sentencing Guidelines to Mirror the Federal System. How the numbers were built: How the Federal Comparison Data Was Built.
Pleas at Courts-Martial
The court-martial records include 16 cases charging frauds against the United States with a plea recorded. This offense has been charged under Article 124 since 2019, and the federal counterpart is the false claims statute, 18 U.S.C. 287. Trial dates run from 2016 to 2025.
Of the 16, 11 (69%) were guilty pleas, 2 (13%) were mixed pleas, and 3 (19%) were not-guilty pleas. Another 3 courts-martial charging this offense have no plea recorded, and they are not in these percentages.
A court-martial is contested when the accused pleads not guilty to at least one charge. Mixed pleas and not-guilty pleas are both contested cases.
Plea Agreements
The records show whether there was a plea agreement for 7 guilty pleas, and all 7 had one. That is a very small base, and plea agreement records come mostly from the Army, Navy, and Marine Corps.
Federal records give a larger count. Among federal guilty pleas, 91% had a written plea agreement and 9% were straight pleas with no agreement.
Guilty Pleas by Service
The Army had 8 cases with a plea recorded, and 5 were guilty pleas. The Air Force had 4 cases, and all 4 were guilty pleas. The Navy had 4 cases, and 2 were guilty pleas.
The Marine Corps does not appear in the table. Air Force plea information is missing for most trials before 2020, so the Air Force count is incomplete.
| Service | Cases with a plea recorded | Guilty pleas | Share |
|---|---|---|---|
| Army | 8 | 5 | 5 of 8 |
| Air Force | 4 | 4 | 4 of 4 |
| Navy | 4 | 2 | 2 of 4 |
Federal Guilty Pleas Among People Sentenced
The U.S. Sentencing Commission counted 437 people sentenced under guideline §2B1.1 with a conviction under 18 U.S.C. 287 in fiscal years 2016 to 2025. Of those, 378 (86%) pleaded guilty and 59 were convicted at trial.
This count includes only people who were convicted and sentenced. Dismissals and acquittals are not in it, which means it cannot show how often federal cases end without a conviction.
Federal Guilty Pleas Among All Defendants Whose Cases Ended
The Federal Judicial Center counted 486 defendants charged under 18 U.S.C. 287 whose cases ended in the same fiscal years. Of these, 418 (86%) pleaded guilty, 42 (9%) had their cases dismissed, and 26 (5%) went to trial.
A total of 441 (91%) were convicted, by plea or at trial. Of the 26 trials, 3 ended in an acquittal. Jury trials numbered 25, with 2 acquittals, and 1 bench trial, decided by a judge, ended in an acquittal.
Year-by-Year Pleas
The federal guilty plea rate was 67% in fiscal year 2022 and 100% in fiscal years 2021 and 2025. The other years were from 79% to 90%.
The court-martial table shows no cases with a plea recorded from 2016 through 2020. From 2021, the yearly counts are 1, 2, 1, 5, and 7 cases, so a single case changes the rate a great deal.
| Year | Courts-martial: guilty pleas | Federal: pleaded guilty |
|---|---|---|
| 2016 | 0 of 0 (none) | 90% |
| 2017 | 0 of 0 (none) | 87% |
| 2018 | 0 of 0 (none) | 87% |
| 2019 | 0 of 0 (none) | 81% |
| 2020 | 0 of 0 (none) | 79% |
| 2021 | 0 of 1 (0 of 1) | 100% |
| 2022 | 2 of 2 (2 of 2) | 67% |
| 2023 | 1 of 1 (1 of 1) | 79% |
| 2024 | 5 of 5 (5 of 5) | 85% |
| 2025 | 3 of 7 (3 of 7) | 100% |
What the Comparison Cannot Show
The court-martial rate is lower than the federal rates, but the groups differ. The court-martial count is small, begins mostly in 2021, and counts cases by trial date. The federal counts are by fiscal year.
A guilty plea rate does not show the strength of the evidence or whether a charge was reduced in exchange for a plea. The records do not show the facts of any case or the sentence that followed.
How We Counted
Courts-martial: every court-martial charging frauds against the United States (Article 124 since 2019; federal false claims, 18 U.S.C. 287) with a trial date in 2016 to 2025 and a plea recorded (16). Federal: people sentenced under guideline §2B1.1 cases with a conviction under 18 U.S.C. 287 (false claims) (437, U.S. Sentencing Commission) and defendants charged under 18 U.S.C. 287 whose cases ended (486, Federal Judicial Center), fiscal years 2016 to 2025.
Federal fiscal years run from October 1 to September 30. No person, judge, or lawyer is identified in any of these records.
What to Keep in Mind
Who is in each set of numbers. The federal sentencing numbers come from the U.S. Sentencing Commission. They count only people who were convicted and sentenced in federal district court. People whose cases were dismissed or who were acquitted are not in them. The military numbers come from court-martial results, which include acquittals. To compare acquittal or dismissal rates, the federal side uses a different source: the Federal Judicial Center's case data, which counts every defendant whose case ended.
Different cases reach each system. Federal prosecutors bring a narrow set of cases. In fiscal year 2024, immigration and drug trafficking cases were 59% of everyone sentenced in federal court (36,664 of 61,678). Many crimes that the military prosecutes, such as most assaults, most sexual assaults between adults, and drug use, are usually state crimes for civilians and reach federal court only in special situations, such as on federal land or in Indian Country. A federal case and a court-martial for the same crime can involve different kinds of facts.
Time periods. Federal numbers are by federal fiscal year (October 1 to September 30), based on the sentencing date. The military numbers are by trial date. Neither source has the date of the offense, so a change in law shows up in either data set gradually.
Offense categories do not line up exactly. Each comparison uses a federal offense group chosen to match the military article as closely as possible (see the crosswalk). Some matches are close; others are partial. The post says which federal guideline or statute was used and why it is not an exact match.
Plea agreements work differently. In federal court, most plea agreements do not bind the judge on the sentence. Since 2019, a military plea agreement can set a minimum and maximum sentence that the military judge must follow if the judge accepts the agreement. The federal numbers count anyone who pleaded guilty, with or without a written agreement.
How "plea" and "trial" are counted. In the federal sentencing numbers, "trial" means the person was convicted after a trial, including people who pleaded guilty to some counts and went to trial on others. People acquitted at trial are not in these numbers at all (see "Who is in each set of numbers"). In the federal case data, the trial rate counts both convictions and acquittals at trial among all defendants whose cases ended, including dismissed cases. Military numbers count contested cases that reached a verdict. These denominators are not the same, and each post states the one it uses.
Related Analysis
- Military Moves Toward Sentencing Guidelines to Mirror the Federal System (the background article)
- Federal Prosecution Analysis (all federal posts)
- How the Federal Comparison Data Was Built (sources and method)
- Stealing From the Government: 18 U.S.C. 641 and False Claims vs. Articles 121 and 124 (overview)
- False Claims Against the United States Sentences: Federal Court vs. Courts-Martial, 2016–2025
- Article 124 UCMJ: Frauds Against the United States (law firm reference page)
- U.S. Sentencing Commission, Individual Offender Datafiles (source)
- Federal Judicial Center, Integrated Database (criminal defendants) (source)
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.