Guilty Pleas in Obstruction of Justice Cases: Federal Court vs. Courts-Martial
Guilty pleas were 69% of the 338 obstruction of justice (Article 131b) courts-martial with a plea recorded from 2016 to 2025: 232 cases. In federal court, 82% of the 1,256 people sentenced under guideline §2J1.2 in fiscal years 2016 to 2025 had pleaded guilty. The federal rate was higher overall, an
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In brief: Guilty pleas were 69% of the 338 obstruction of justice (Article 131b) courts-martial with a plea recorded from 2016 to 2025: 232 cases. In federal court, 82% of the 1,256 people sentenced under guideline §2J1.2 in fiscal years 2016 to 2025 had pleaded guilty. The federal rate was higher overall, and the difference varied by year and by service.
This post uses the U.S. Sentencing Commission's records of 1,256 people sentenced in federal court in fiscal years 2016 to 2025 and 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). 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 Many Obstruction Courts-Martial Ended in Guilty Pleas?
Court-martial records list a plea for 338 cases charging Article 131b, with trial dates from 2016 to 2025. Of those, 232 (69%) were guilty pleas, 27 (8%) were mixed pleas, and 79 (23%) were not-guilty pleas. Another 12 cases have no plea recorded and are left out of these shares.
A mixed plea means the accused pleaded guilty to some charges and not guilty to others. Those cases are contested, so they are counted apart from the guilty pleas.
Did the Guilty Plea Rate Differ by Service?
The Marine Corps had the highest share of guilty pleas, 77% of 96 cases with a plea recorded. The Navy followed with 74% of 101 cases. The Air Force had 61% of 31 cases, and the Army had 58% of 110 cases.
Air Force plea information is missing for most trials before 2020, so the Air Force share rests on a small and partial group of cases.
| Service | Cases with a plea recorded | Guilty pleas | Share |
|---|---|---|---|
| Army | 110 | 64 | 58% |
| Air Force | 31 | 19 | 61% |
| Navy | 101 | 75 | 74% |
| Marine Corps | 96 | 74 | 77% |
What Does the Federal Data Show?
The U.S. Sentencing Commission counts only people who were convicted and sentenced. Of 1,256 people sentenced under guideline §2J1.2 (obstruction of justice) in fiscal years 2016 to 2025, 1,031 (82%) pleaded guilty and 225 were convicted at trial.
Among the federal guilty pleas, 91% had a written plea agreement and 8% were straight pleas with no agreement. In the court-martial records, 188 of the 197 guilty pleas with a known agreement status (95%) had a plea agreement. Those agreement records come mostly from the Army, Navy, and Marine Corps.
A Second Federal Measure That Includes Dismissals
The Federal Judicial Center counts every defendant whose case ended, not only those who were sentenced. It found 1,590 defendants charged under 18 U.S.C. 1503, 1505, 1512, or 1519 in fiscal years 2016 to 2025. Of those, 1,037 (65%) pleaded guilty, 226 (14%) had their cases dismissed, and 327 (21%) went to trial.
The 65% figure is lower than the 82% figure because the measures start with different groups. Dismissed cases are in the 1,590 and not in the 1,256. Overall, 1,312 of the 1,590 defendants (83%) were convicted by plea or at trial.
Year-by-Year Comparison
The federal rate stayed between 80% and 92% in every fiscal year except 2023, when it was 55%. The court-martial rate moved over a wider range, from 94% in 2017 to 53% in 2024. In 2019, the rates were the same, at 86%.
From 2021 to 2025, the court-martial share was lower than the federal share in every year except 2023, when it was 76% against the federal 55%. The records cannot show whether the 2023 federal figure reflects a change in practice or a feature of the data.
| Year | Courts-martial: guilty pleas | Federal: pleaded guilty |
|---|---|---|
| 2016 | 9 of 11 (82%) | 82% |
| 2017 | 15 of 16 (94%) | 92% |
| 2018 | 16 of 21 (76%) | 88% |
| 2019 | 25 of 29 (86%) | 86% |
| 2020 | 24 of 31 (77%) | 91% |
| 2021 | 38 of 60 (63%) | 86% |
| 2022 | 31 of 50 (62%) | 88% |
| 2023 | 26 of 34 (76%) | 55% |
| 2024 | 25 of 47 (53%) | 80% |
| 2025 | 23 of 39 (59%) | 85% |
What the Records Cannot Show
The court-martial figure counts cases with a plea recorded, and the federal figure counts people sentenced. Neither group includes cases that never reached a plea.
The records do not show why an accused pleaded guilty or what each plea agreement contained. They show how often each plea occurred, and they do not show how sentences compared between plea and trial.
How We Counted
Courts-martial: every court-martial charging obstruction of justice (Article 131b) with a trial date in 2016 to 2025 and a plea recorded (338). Federal: people sentenced under guideline §2J1.2 (obstruction of justice) (1,256, U.S. Sentencing Commission) and defendants charged under 18 U.S.C. 1503, 1505, 1512, or 1519 whose cases ended (1,590, 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)
- Obstruction of Justice and Perjury: Federal vs. Court-Martial Sentences (overview)
- Obstruction of Justice Sentences Since the 2023 Military Sentencing Reform: What the Data Shows So Far
- Obstruction of Justice Charges: Federal Trial Acquittals vs. Contested Army Courts-Martial
- Obstruction of Justice Charges: How Often Federal Trials and Courts-Martial End in Acquittal
- 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 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)
- Air Force Article 131b Cases by the Numbers, 2016–2025 (court-martial data)
- What Sentence Follows an Air Force Obstruction Conviction? (court-martial data)
- Pleading Guilty to Article 131b in the Air Force: What Sentences Followed? (court-martial data)
- 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)
- Article 131b UCMJ: Obstructing Justice (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.