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Understanding Trends

Navy-Marine Corps Cases Charging Both Article 131b and Article 134

19 Navy and Marine Corps courts-martial from 2021–2025 charged both Article 131b (obstruction) and Article 134 (general article). The median confinement was 2 years, compared with 9 months in all Navy and Marine Corps Article 131b cases.

Understanding Trends in Military Practice · 4 min read

Trends › By Offense › Article 131b › Navy-Marine Corps, with Article 134

Short answer: 19 Navy and Marine Corps courts-martial from 2021–2025 charged both Article 131b (obstruction) and Article 134 (general article). The median confinement was 2 years, compared with 9 months in all Navy and Marine Corps Article 131b cases. A punitive discharge followed 94% of enlisted convictions, compared with 72% across those Article 131b cases.

Based on 19 cases · 2021–2025 · Navy and Marine Corps records · data updated October 24, 2026

Long Confinement Terms

All 19 cases ended in a conviction, and 18 of the 19 sentences included confinement. The median term was 2 years. In all Navy and Marine Corps Article 131b cases in 2021–2025, the median was 9 months.

A quarter of the confinement terms were 3 years or longer. These figures are adjudged sentences, as set at trial before any plea-agreement cap, clemency, or appeal. Each sentence covers every charge in the case, not only the obstruction count.

More Dishonorable Than Bad-Conduct Discharges

94% of enlisted convictions included a punitive discharge. There were 9 dishonorable discharges and 8 bad-conduct discharges. In Navy and Marine Corps-wide Article 131b cases, the share with a punitive discharge was 72%.

A dishonorable discharge is the more severe punitive discharge for enlisted members, and only a general court-martial can impose it.

Most Cases at the General Court-Martial Level

15 of the 19 cases (79%) were general courts-martial. Special courts-martial made up the rest. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge.

How the Accused Pleaded

13 accused pleaded guilty, and 6 contested at least one charge by pleading not guilty to it. The contested share was 32%, about the same as the 31% in all Navy and Marine Corps Article 131b cases in 2021–2025.

Rank of Those Charged

Junior enlisted members (E-1 to E-4) were 61% of the accused, and NCOs were 39%. No officers appear. Across all Navy and Marine Corps Article 131b cases in 2021–2025, junior enlisted members were 69%.

Other Charges in the Same Cases

Article 131b never appeared alone in these cases. Besides Article 134, the most common charges were Article 92 (orders violation) in 4 cases, Article 121 (larceny) in 4, Article 107 (false official statement) in 3, and Article 120b (child sexual abuse) in 2.

Trials by Year

Trials ran from February 2021 to June 2025. By year, there were 10 in 2021, 0 in 2022, 6 in 2023, 1 in 2024, and 2 in 2025.

Rule Changes and What the Records Do Not Show

For covered offenses, such as sexual assault, domestic violence, and murder, the choice to prosecute moved from commanders to special trial counsel on December 28, 2023. Sentencing also changed: in a case where all guilty findings are for offenses after December 27, 2023, a military judge decides the sentence using new sentencing parameters.

The records give trial dates, not offense dates, so trials from 2024 on can fall under either the old or the new rules. The records do not describe the evidence or the plea terms. Cases handled by nonjudicial punishment or administrative separation are not included. A sentence without a punitive discharge does not rule out a later administrative separation.

Dates and sources for the law changes mentioned here: UCMJ change timeline.

How We Counted

Navy and Marine Corps courts-martial with trial dates in 2021–2025 that charged both Article 131b and Article 134 (19 cases), compared with all 106 Navy and Marine Corps Article 131b cases in those years.

Source: public court-martial records (Article 140a, UCMJ) in Military Trial Results, data updated October 24, 2026. Definitions, sources, and known gaps: how this data was built. Errors: content@bodiesburied.com.

Compare: federal court. Obstruction of Justice and Perjury: Federal vs. Court-Martial Sentences

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.

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