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# Guilty Pleas in Manslaughter Cases: Federal Court vs. Courts-Martial
- URL: https://www.bodiesburied.com/trends/federal-manslaughter-guilty-plea-rate-vs-courts-martial/
- Published: 2026-11-03T01:39:02.000Z
- Updated: 2026-11-03T01:39:02.000Z
- Description: In federal court, 686 of 737 people sentenced for manslaughter pleaded guilty (93%), in fiscal years 2016 to 2025. Among 36 courts-martial for manslaughter under Article 119 with a plea recorded, trial dates 2016 to 2025, 20 were guilty pleas (56%). Guilty pleas were more common in federal court tha
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Federal

[Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › [Murder and Manslaughter](https://www.bodiesburied.com/trends/federal-murder-manslaughter-vs-courts-martial/) › Manslaughter: Guilty Pleas

**In brief:** In federal court, 686 of 737 people sentenced for manslaughter pleaded guilty (93%), in fiscal years 2016 to 2025\. Among 36 courts-martial for manslaughter under Article 119 with a plea recorded, trial dates 2016 to 2025, 20 were guilty pleas (56%). Guilty pleas were more common in federal court than in courts-martial.

Updated November 2, 2026 · Sources: U.S. Sentencing Commission and Federal Judicial Center, fiscal years 2016–2025 · Military Trial Results

This post uses the U.S. Sentencing Commission's records of 737 people sentenced in federal court in fiscal years 2016 to 2025 and the Federal Judicial Center's records of 599 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](https://www.bodiesburied.com/trends/federal/) series, which builds on [Military Moves Toward Sentencing Guidelines to Mirror the Federal System](https://www.bodiesburied.com/trends/military-sentencing-guidelines-federal-system/). How the numbers were built: [How the Federal Comparison Data Was Built](https://www.bodiesburied.com/trends/federal-data-methodology/).

## Federal Guilty Pleas for Manslaughter

The U.S. Sentencing Commission counted 737 people sentenced under the guidelines for voluntary manslaughter (§2A1.3) or involuntary manslaughter (§2A1.4). Of them, 686 pleaded guilty (93%), and 51 were convicted at trial.

Among the guilty pleas, 88% had a written plea agreement. The other 12% were straight pleas with no agreement.

## A Second Federal Count, Including Dismissals

The Federal Judicial Center counts differently. It covers 599 defendants charged under 18 U.S.C. 1112 whose cases ended in the same fiscal years. Of these, 551 pleaded guilty (92%), 20 had their cases dismissed (3%), and 28 went to trial (5%).

The first count includes only people who were convicted and sentenced. The second starts with every case that ended, so dismissals and acquittals are in its base. That is why the plea shares differ slightly. In the second count, 569 of 599 (95%) were convicted.

## Pleas in Courts-Martial

The court-martial records show a plea for 36 manslaughter cases. There were 20 guilty pleas (56%), 4 mixed pleas (11%), and 12 not-guilty pleas (33%). Another 6 cases have no plea recorded and are not in these percentages.

A mixed plea means guilty to some charges and not guilty to others. The court-martial base includes acquittals, because it counts every case with a plea recorded.

## Plea Agreements

Plea agreement records exist for 16 court-martial guilty pleas, and 15 of those (94%) had an agreement. These records are mostly from the Army, Navy, and Marine Corps.

The federal share with a written agreement was 88%. These figures are close, but the court-martial count is only 16 cases.

## Pleas by Service and by Year

The Army had 13 cases with a plea recorded, and 10 were guilty pleas (77%). The Marine Corps had 10, with 4 guilty pleas (40%). The Navy had 4 of 7, and the Air Force had 2 of 6.

Air Force plea information is missing for most trials before 2020, so the Air Force row is incomplete.

| Service      | Cases with a plea recorded | Guilty pleas | Share  |
| ------------ | -------------------------- | ------------ | ------ |
| Army         | 13                         | 10           | 77%    |
| Air Force    | 6                          | 2            | 2 of 6 |
| Navy         | 7                          | 4            | 4 of 7 |
| Marine Corps | 10                         | 4            | 40%    |

## Yearly Rates and Their Limits

Federal guilty plea shares stayed between 86% and 97% in every year. Court-martial counts are small each year. The largest was 12 cases with a plea recorded in 2021, and 4 of them were guilty pleas.

In 2019, 0 of 2 court-martial cases were guilty pleas, and in 2025 it was 5 of 8\. Those swings reflect very few cases.

| Year | Courts-martial: guilty pleas | Federal: pleaded guilty |
| ---- | ---------------------------- | ----------------------- |
| 2016 | 1 of 1 (1 of 1)              | 96%                     |
| 2017 | 0 of 0 (none)                | 96%                     |
| 2018 | 1 of 1 (1 of 1)              | 97%                     |
| 2019 | 0 of 2 (0 of 2)              | 95%                     |
| 2020 | 2 of 2 (2 of 2)              | 89%                     |
| 2021 | 4 of 12 (33%)                | 96%                     |
| 2022 | 2 of 2 (2 of 2)              | 92%                     |
| 2023 | 3 of 4 (3 of 4)              | 91%                     |
| 2024 | 2 of 4 (2 of 4)              | 86%                     |
| 2025 | 5 of 8 (5 of 8)              | 96%                     |

## What the Records Cannot Show

The records do not show why a plea was entered, what was offered, or what evidence existed. They also do not show whether the missing plea records differ from the recorded ones.

### How We Counted

Courts-martial: every court-martial charging manslaughter (Article 119) with a trial date in 2016 to 2025 and a plea recorded (36). Federal: people sentenced under guideline §2A1.3 (voluntary manslaughter) or §2A1.4 (involuntary manslaughter) (737, U.S. Sentencing Commission) and defendants charged under 18 U.S.C. 1112 whose cases ended (599, 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](https://www.bodiesburied.com/trends/military-sentencing-guidelines-federal-system/) (the background article)
- [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) (all federal posts)
- [How the Federal Comparison Data Was Built](https://www.bodiesburied.com/trends/federal-data-methodology/) (sources and method)
- [Murder and Manslaughter: Federal vs. Court-Martial Sentences, 2016–2025](https://www.bodiesburied.com/trends/federal-murder-manslaughter-vs-courts-martial/) (overview)
- [Manslaughter Charges: How Often Federal Trials and Courts-Martial End in Acquittal](https://www.bodiesburied.com/trends/federal-manslaughter-acquittal-rate-vs-courts-martial/)
- [Manslaughter Convictions of Junior Enlisted (E-1 to E-4): Courts-Martial Compared With Federal Court](https://www.bodiesburied.com/trends/federal-manslaughter-junior-enlisted-vs-federal-court/)
- [Manslaughter Convictions of NCOs (E-5 to E-9): Courts-Martial Compared With Federal Court](https://www.bodiesburied.com/trends/federal-manslaughter-ncos-vs-federal-court/)
- [Manslaughter: Sentences After a Guilty Plea vs. After Trial, Federal Court and Courts-Martial](https://www.bodiesburied.com/trends/federal-manslaughter-plea-vs-trial-sentences/)
- [Manslaughter Sentences: Federal Court vs. Courts-Martial, 2016–2025](https://www.bodiesburied.com/trends/federal-manslaughter-sentences-vs-courts-martial/)
- [Manslaughter: Federal Sentences vs. Army Courts-Martial](https://www.bodiesburied.com/trends/federal-manslaughter-vs-army/)
- [Guilty Pleas in Army Manslaughter Cases: How Often, and What Came Next](https://www.bodiesburied.com/trends/army-article-119-plea-2021-2025/) (court-martial data)
- [Navy-Marine Corps Article 119 Cases by the Numbers, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-119-trend-2017-2025/) (court-martial data)
- [What Sentence Follows a Navy-Marine Corps Manslaughter Conviction?](https://www.bodiesburied.com/trends/navy-marine-corps-article-119-sent-2017-2025/) (court-martial data)
- [Article 119 (Manslaughter): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-119-courts-martial/) (court-martial data)
- [Article 119 UCMJ: Voluntary and Involuntary Manslaughter](https://www.ucmj-defender.com/practice-areas/court-martial/article-119/?ref=bodiesburied.com) (law firm reference page)
- [U.S. Sentencing Commission, Individual Offender Datafiles](https://www.ussc.gov/research/datafiles/commission-datafiles?ref=bodiesburied.com) (source)
- [Federal Judicial Center, Integrated Database (criminal defendants)](https://www.fjc.gov/research/idb?ref=bodiesburied.com) (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](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.