Obstruction of Justice Charges: Federal Trial Acquittals vs. Contested Army Courts-Martial
Of 46 contested Army courts-martial for obstruction of justice (Article 131b) that reached a verdict from 2021 to 2025, 13 (28%) ended in a full acquittal. In federal court, 52 of 327 obstruction trials (16%) ended in an acquittal in fiscal years 2016 to 2025. Who decided guilt mattered in the Army
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In brief: Of 46 contested Army courts-martial for obstruction of justice (Article 131b) that reached a verdict from 2021 to 2025, 13 (28%) ended in a full acquittal. In federal court, 52 of 327 obstruction trials (16%) ended in an acquittal in fiscal years 2016 to 2025. Who decided guilt mattered in the Army data: 1 of 21 judge-alone cases ended in a full acquittal, and 10 of 23 member cases did.
This post uses the Federal Judicial Center's records of 1,590 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). The series also draws on the U.S. Sentencing Commission's records of 659,036 people sentenced in fiscal years 2016 to 2025. 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.
Did the Decision-Maker Change the Army Result?
In the 21 Army cases decided by a judge alone, 1 ended in a full acquittal (5%). In the 23 cases decided by members, 10 did (43%). Full acquittals were more common when members decided guilt.
Within the members group, 9 of 17 cases with enlisted members (53%) ended in a full acquittal, and 1 of 6 with officer members did. 2 more cases had no forum listed, and both ended in a full acquittal. The group sizes are small, so each figure can move with a few cases.
The records show the difference. They do not show why it exists.
How Often Were Army Cases Partial Acquittals?
A partial acquittal means not guilty of at least one charge but guilty of another. In the Army data, 29 of the 46 contested cases (63%) ended that way. Full acquittals were 13 cases (28%).
A court-martial is contested when the accused pleads not guilty to at least one charge. The 46 cases are contested cases that reached a verdict, not all Army obstruction cases.
What Did Each Year Show?
By year, the Army had full acquittals in 2 of 10 contested cases in 2021 and 4 of 12 in 2022. The counts were 3 of 7 in 2023, 4 of 12 in 2024, and 0 of 5 in 2025.
The yearly counts range from 5 to 12 cases. With numbers this small, one case moves a yearly rate by a large amount.
| Year | Army: full acquittals of contested cases |
|---|---|
| 2021 | 2 of 10 |
| 2022 | 4 of 12 |
| 2023 | 3 of 7 |
| 2024 | 4 of 12 |
| 2025 | 0 of 5 |
What Did Federal Court Show?
The Federal Judicial Center counted 1,590 defendants charged under 18 U.S.C. 1503, 1505, 1512, or 1519 whose cases ended in fiscal years 2016 to 2025. Of these, 1,037 (65%) pleaded guilty, 226 (14%) had their cases dismissed, and 327 (21%) went to trial.
Of the 327 trials, 52 ended in an acquittal (16%). Jury trials numbered 290, with 48 acquittals (17%). Bench trials, decided by a judge, numbered 37, with 4 acquittals (11%).
The Army full acquittal rate of 28% was higher than the federal rate of 16%. The federal jury rate was 17% and the federal bench rate was 11%, so neither matches the Army split by forum.
Why Are These Rates Not the Same Measure?
The federal figure is a share of trials. The Army figure is a share of contested cases that reached a verdict. Most federal cases end in a guilty plea or a dismissal before trial, and 1,312 of the 1,590 defendants (83%) were convicted by plea or at trial.
Federal case data does not report partial acquittals separately. The Army figure of 28% leaves out the 29 partial acquittals, and the federal data has no matching category.
The Federal Judicial Center data counts every defendant whose case ended, including dismissals and acquittals. The Army data is by trial date, and the federal data is by fiscal year.
What Can the Records Not Show?
The records do not show the evidence in any case, the charges that were acquitted, or why an accused chose a trial. They do not show whether a federal prosecutor would have brought the same Army cases, since a federal felony needs a grand jury indictment and the military process works differently.
The comparison is between rates that count different groups. It cannot show that one system acquits more than the other.
How We Counted
Army courts-martial charging obstruction of justice (Article 131b) with trial dates in 2016 to 2025 that were contested and reached a verdict (46). Federal: defendants charged under 18 U.S.C. 1503, 1505, 1512, or 1519 whose cases ended in fiscal years 2016 to 2025 (1,590), Federal Judicial Center.
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.
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)
- Obstruction of Justice and Perjury: Federal vs. Court-Martial Sentences (overview)
- Obstruction of Justice Charges: Federal Trial Acquittals vs. Contested Marine Corps Courts-Martial
- Obstruction of Justice Charges: Federal Trial Acquittals vs. Contested Navy Courts-Martial
- Obstruction of Justice Sentences Since the 2023 Military Sentencing Reform: What the Data Shows So Far
- Obstruction of Justice Charges: How Often Federal Trials and Courts-Martial End in Acquittal
- Guilty Pleas in Obstruction of Justice Cases: Federal Court vs. Courts-Martial
- Obstruction of Justice Convictions of Junior Enlisted (E-1 to E-4): Courts-Martial Compared With Federal Court
- How Has Article 131b Changed in Army Courts-Martial Since 2021? (court-martial data)
- How Much Confinement for an Article 131b Conviction in the Army? (court-martial data)
- How Often Are Contested Army Article 131b Cases Acquitted? (court-martial data)
- Pleading Guilty to Article 131b in the Army: What Sentences Followed? (court-martial data)
- Article 131b (Obstruction, Numbered Since 2019): Court-Martial Data and Trends (court-martial data)
- Army Courts-Martial: Data and Trends (court-martial data)
- Article 131b UCMJ: Obstructing Justice (law firm reference page)
- Forum Selection (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.