Obstruction of Justice Charges: Federal Trial Acquittals vs. Contested Navy Courts-Martial
Of 26 contested Navy courts-martial for obstruction of justice (Article 131b) that reached a verdict from 2016 to 2025, 4 (15%) ended in a full acquittal. In federal court, 52 of 327 obstruction trials (16%) ended in an acquittal in fiscal years 2016 to 2025. The rates are about the same, but the Na
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In brief: Of 26 contested Navy courts-martial for obstruction of justice (Article 131b) that reached a verdict from 2016 to 2025, 4 (15%) ended in a full acquittal. In federal court, 52 of 327 obstruction trials (16%) ended in an acquittal in fiscal years 2016 to 2025. The rates are about the same, but the Navy count is small and they do not measure the same group.
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.
How Often Did Contested Navy Cases End in Acquittal?
The Navy records show 26 contested obstruction cases that reached a verdict. Of these, 4 ended in a full acquittal, a rate of 15%. Another 9 (35%) were partial acquittals, meaning not guilty of at least one charge but guilty of another.
A court-martial is contested when the accused pleads not guilty to at least one charge. The 26 cases do not include cases where the accused pleaded guilty to every charge.
Who Decided Guilt in Navy Cases?
Navy and Marine Corps records usually do not show who decided guilt, a judge or members. For 17 of the 26 Navy cases no forum was listed, and 4 of those (24%) ended in a full acquittal.
A judge alone decided 8 cases, and none ended in a full acquittal. Members decided 1 case, and it did not end in a full acquittal. One more case had enlisted members listed as the forum, also without a full acquittal.
Because most cases have no forum, the Navy data cannot support a comparison between judges and members.
What Did Each Year Show?
The Navy had no more than 5 contested verdicts in any year. Full acquittals were 1 of 1 in 2017, 2 of 4 in 2018, and 1 of 3 in 2019. Every other listed year had none: 0 of 1 in 2016, 0 of 4 in 2020, 0 of 1 in 2021, 0 of 4 in 2022, 0 of 3 in 2024, and 0 of 5 in 2025.
The table has no row for 2023. All 4 Navy full acquittals fall in 2017 to 2019, and none appear after that. The records cannot show why.
| Year | Navy: full acquittals of contested cases |
|---|---|
| 2016 | 0 of 1 |
| 2017 | 1 of 1 |
| 2018 | 2 of 4 |
| 2019 | 1 of 3 |
| 2020 | 0 of 4 |
| 2021 | 0 of 1 |
| 2022 | 0 of 4 |
| 2024 | 0 of 3 |
| 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.
The 52 acquittals were 16% of the 327 trials. Jury trials numbered 290, with 48 acquittals (17%). Bench trials numbered 37, with 4 acquittals (11%). In all, 1,312 of the 1,590 defendants (83%) were convicted.
Can the Navy and Federal Rates Be Compared?
The Navy rate of 15% is about the same as the federal rate of 16%, but the denominators differ. The Navy figure is a share of contested cases that reached a verdict, and the federal figure is a share of trials.
Federal case data does not report partial acquittals separately, and the Navy data does. A federal felony needs a grand jury indictment, and a court-martial has no grand jury, so the cases reaching trial may differ in each system.
With 4 full acquittals in the Navy, one more or one fewer would change the rate. The comparison cannot show that the Navy and federal courts acquit at the same level.
What Do the Records Not Show?
The records do not show the evidence, the charges on which an accused was acquitted, or the reasons for any verdict. The Navy data is by trial date, and the federal data is by fiscal year.
The Federal Judicial Center data counts every defendant whose case ended, including dismissals. Navy cases that never reached a verdict are not in the 26.
How We Counted
Navy courts-martial charging obstruction of justice (Article 131b) with trial dates in 2016 to 2025 that were contested and reached a verdict (26). 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 Army Courts-Martial
- Obstruction of Justice Charges: Federal Trial Acquittals vs. Contested Marine Corps 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
- Is Navy-Marine Corps Obstruction Prosecution Rising or Falling? Article 131b, 2017–2025 (court-martial data)
- How Much Confinement for an Article 131b Conviction in the Navy-Marine Corps? (court-martial data)
- Not Guilty Pleas in Navy-Marine Corps Article 131b Cases: What Happened at Trial (court-martial data)
- Pleading Guilty to Article 131b in the Navy-Marine Corps: What Sentences Followed? (court-martial data)
- Article 131b (Obstruction, Numbered Since 2019): Court-Martial Data and Trends (court-martial data)
- Navy-Marine Corps 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.