Obstruction of Justice: Courts-Martial at San Diego vs. Federal Court in the Southern District of California
Obstruction of justice convictions at courts-martial tried in San Diego carried a median adjudged confinement of 5.9 months across 27 convictions from 2016 to 2024. In the Southern District of California, the median federal prison term under guideline §2J1.2 was 18 months for the 12 of 18 people who
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In brief: Obstruction of justice convictions at courts-martial tried in San Diego carried a median adjudged confinement of 5.9 months across 27 convictions from 2016 to 2024. In the Southern District of California, the median federal prison term under guideline §2J1.2 was 18 months for the 12 of 18 people who received prison. The federal figures cover the whole district, not the military installations in San Diego.
This post uses the U.S. Sentencing Commission's records of 18 people sentenced in federal court in fiscal years 2016 to 2025, compared with court-martial results from this site's Military Trial Results data (updated November 2, 2026). Acquittals and dismissals come from a second source, the Federal Judicial Center's records of 753,808 federal defendants whose cases ended 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.
What Is Being Compared
San Diego is in the federal Southern District of California. The 18 federal sentences counted here are obstruction cases from anywhere in that district. Most did not involve service members, and none were selected because of a link to a base.
The military count uses courts-martial where the records list the trial location as "Marine Corps Recruit Depot San Diego", "San Diego", or "San Diego, California". Of the 27 convictions under Article 131b, 24 were Navy cases and 3 were Marine Corps cases. These records cannot show which court any case would have reached under the other system.
Court-martial years are calendar years by trial date. The federal numbers use fiscal years, October 1 to September 30, and here span fiscal years 2016 to 2024.
How Long Were Sentences on Each Side?
The San Diego median confinement of 5.9 months was lower than the district's 18-month median prison term. A quarter of San Diego sentences were 12 months or more. In the district, a quarter of prison terms were 24.8 months or more, and a quarter were 12 months or less.
Confinement itself was more frequent in San Diego. It was part of 23 of the 27 sentences recorded (85%). In the district, 12 of 18 people (67%) received a prison term, and 6 (33%) received probation only.
Military sentences here are as adjudged, before any clemency or appeal. Federal terms are as imposed, not as served.
| Courts-martial at San Diego | Federal court, Southern District of California | |
|---|---|---|
| Convictions or people sentenced | 27 | 18 |
| Sentenced to confinement or prison | 85% | 67% |
| Median confinement or prison | 5.9 months | 18 months |
| A quarter received this or more | 12 months | 24.8 months |
| Pleaded guilty | 21 of 26 with a plea recorded (81%) | 94% |
| Mandatory minimum applied | See the caveats | 0 of 18 with the information (0%) |
Punitive Discharges Were Less Common in San Diego
Of the 26 enlisted members convicted, 14 (54%) received a punitive discharge: 3 dishonorable discharges and 11 bad-conduct discharges. A punitive discharge is a separate penalty from confinement and has no federal equivalent.
A general court-martial heard 10 of the 27 cases (37%). The remaining convictions came from other court-martial levels.
Sentences in San Diego Over Time and Against All Courts-Martial
Across all courts-martial for obstruction in the data, the median confinement was 10 months, from 329 convictions. The San Diego median of 5.9 months was lower.
Trials in 2016 to 2019 had a median of 5.9 months, based on 12 cases with confinement. Trials in 2020 to 2025 had a median of 5 months, based on 11 cases. The earlier and later medians were about the same. The records give no reason for either figure.
Guilty Pleas, Plea Agreements, and Trials
A guilty plea accounted for 21 of the 26 San Diego convictions with a plea recorded (81%). After a guilty plea, the median confinement was 5.9 months, from 21 cases with confinement. Contested cases ending in conviction had a median of 8 months, but only 2 of those cases included confinement.
In federal court in the district, 94% of people sentenced pleaded guilty, and 100% of those pleas came with a written plea agreement. The median prison term after a guilty plea was 18 months. Only 1 person was convicted after a trial, so no trial median can be compared in a useful way.
Federal Sentences and the Guideline Range
The federal guidelines set a recommended range for every case. A sentence within that range applied to 33% of the district's 18 sentences. Sentences below the range split between those at the government's request, 28%, and those without one, also 28%. Above-range sentences were 11%.
In the district, 67% of people were in criminal history category I, the lowest, and 11% in category VI. No such field exists in court-martial records. Supervised release was ordered for 61%, fines for 33%, and restitution for 28%. A mandatory minimum applied to 0%.
What Cannot Be Read From These Numbers
Nationally, federal courts sentenced 1,256 people under §2J1.2, with a median prison term of 18 months, the same as this district. Both local counts are small. The records do not describe the conduct in any case, and they cannot show whether a person tried in San Diego would have been treated differently in federal court.
How We Counted
Courts-martial with trial dates in 2016 to 2025 whose recorded trial location is San Diego, California, ending in a conviction for obstruction of justice (Article 131b) (27). Federal: people sentenced in fiscal years 2016 to 2025 in the Southern District of California (U.S. Sentencing Commission district label "California South") under guideline §2J1.2 (obstruction of justice) (18). The installation is matched to the federal district for the county where it sits.
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.
No parole in federal prison; credit for good conduct. Federal prison has no parole for crimes committed on or after November 1, 1987. A federal prisoner can earn up to 54 days of good conduct credit for each year of the sentence the judge imposed, which is about 15%. Some federal prisoners can also earn First Step Act time credits, but many offenses make a person ineligible. The numbers in this post are the sentences judges imposed, not the time people actually served.
Military confinement credit and parole. For military sentences adjudged after 2004, good conduct time is 5 days for each month of confinement, about 16%. Military prisoners can also earn up to 8 more days a month for work and programs and up to 2 days a month for special acts, with a limit of 15 days a month in total. Military prisoners can be considered for parole by their service's clemency and parole board. The military numbers in this post are the confinement adjudged at trial, not the time served.
Military sentences include punishments federal sentences do not. A court-martial sentence can include a punitive discharge (bad-conduct discharge, dishonorable discharge, or dismissal for officers), reduction in rank, and forfeiture of pay. These have no federal counterpart. A comparison of months of confinement leaves them out. A short confinement term combined with a dishonorable discharge is a heavier sentence than the months alone show.
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.
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)
- Federal Sentences in the Southern District of California, FY2016–2025 (the federal district)
- Child Pornography: Courts-Martial at San Diego vs. Federal Court in the Southern District of California (same installation)
- Child Sexual Abuse and Enticement: Courts-Martial at San Diego vs. Federal Court in the Southern District of California (same installation)
- Drug Possession: Courts-Martial at San Diego vs. Federal Court in the Southern District of California (same installation)
- Drug Use: Courts-Martial at San Diego vs. Federal Court in the Southern District of California (same installation)
- Drug Distribution: Courts-Martial at San Diego vs. Federal Court in the Southern District of California (same installation)
- Theft and Fraud: Courts-Martial at San Diego vs. Federal Court in the Southern District of California (same installation)
- Obstruction of Justice: Courts-Martial at Camp Lejeune vs. Federal Court in the Eastern District of North Carolina (other installations)
- Obstruction of Justice: Courts-Martial at Camp Pendleton vs. Federal Court in the Southern District of California (other installations)
- Obstruction of Justice: Courts-Martial at Fort Bliss vs. Federal Court in the Western District of Texas (other installations)
- Obstruction of Justice: Courts-Martial at Norfolk vs. Federal Court in the Eastern District of Virginia (other installations)
- Obstruction of Justice: Federal Sentences vs. Air Force Courts-Martial
- Obstruction of Justice: Federal Sentences vs. Army Courts-Martial
- Obstruction of Justice: Federal Sentences vs. Marine Corps Courts-Martial, 2016–2025
- 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.