Pleading Guilty to Article 87a in the Navy-Marine Corps: What Sentences Followed?
The records hold 15 Navy and Marine Corps courts-martial from 2017–2025 where the accused pleaded guilty to charges including Article 87a (resisting apprehension, numbered since 2019).
Understanding Trends in Military Practice · 4 min read
Trends › By Offense › Article 87a › Pleading Guilty to Article 87a in the Na
Short answer: The records hold 15 Navy and Marine Corps courts-martial from 2017–2025 where the accused pleaded guilty to charges including Article 87a (resisting apprehension, numbered since 2019). The median confinement was 9 months, longer than the 6 months for all Navy and Marine Corps guilty pleas in those years, and 10 of 15 convicted enlisted members received a bad-conduct discharge.
Confinement in 14 of 15 Sentences
All 15 cases ended in a conviction on at least one charge, and 14 of the sentences included confinement (93%). The median confinement was 9 months. For all Navy and Marine Corps guilty pleas in those years, the median was 6 months.
Among the sentences that included confinement, a quarter were 1 year or longer. These numbers are adjudged sentences, as imposed at trial and before any plea-agreement cap, clemency, or appeal.
Never the Only Charge
All 15 cases charged at least one article besides Article 87a, so each sentence also reflects other offenses. Article 92 (orders violation) appeared in 5 cases. Article 86 (AWOL) and Article 128 (assault) each appeared in 4. Article 89 (disrespect) and Article 121 (larceny) each appeared in 3.
Bad-Conduct Discharges in 10 Cases
10 of 15 convicted enlisted members received a punitive discharge. All 10 were bad-conduct discharges, and 0 were dishonorable. In all Navy and Marine Corps guilty pleas in those years, the punitive discharge share was 60%.
Members whose sentence did not include a punitive discharge could still be separated administratively, which these records do not show.
Junior Enlisted Accused
By rank, 14 of the accused were junior enlisted, 1 was an NCO, and 0 were officers. The group was more junior than all Navy and Marine Corps guilty pleas in those years.
General and Special Courts-Martial
General courts-martial made up 27% of these cases (4 of 15), and special courts-martial made up the rest. Only a general court-martial can impose a dishonorable discharge or confinement beyond one year.
Trial Years
The 15 trials took place between September 2017 and December 2025: 2 in 2017, 1 in 2018, 0 in 2019, 0 in 2020, 3 in 2021, 2 in 2022, 1 in 2023, 4 in 2024, and 2 in 2025. Navy and Marine Corps records before December 2020 often omit the plea, and these counts use only records that list one.
Law Changes Across the Window
The Military Justice Act of 2016 took effect on January 1, 2019, so the 2017 and 2018 trials here came under the earlier rules. The act added written plea agreements, fixed panel sizes, and a judge-alone special court-martial capped at six months with no punitive discharge.
Starting December 28, 2023, special trial counsel rather than commanders decide whether covered offenses, such as sexual assault, domestic violence, and murder, are prosecuted. If all guilty findings are for offenses after December 27, 2023, the military judge sentences within new parameters. With no offense dates in the records, the 2024 and 2025 trials cannot be sorted by rule set.
Not in These Records
The records show charges, pleas, findings, and sentences. They do not describe the evidence or the plea terms, and conduct handled by nonjudicial punishment or administrative separation is not included.
Dates and sources for the law changes mentioned here: UCMJ change timeline.
How We Counted
Navy and Marine Corps courts-martial tried 2017–2025: where the accused pleaded guilty to charges including Article 87a (resisting apprehension) (15 cases), compared with all Navy and Marine Corps guilty pleas 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.
Related Analysis
- Article 87a (Resisting Apprehension, Numbered Since 2019): Court-Martial Data and Trends (hub)
- Sentences (hub)
- Fewer or More? Resisting Apprehension Charges at Navy-Marine Corps Courts-Martial, 2017–2025
- What Sentence Follows a Navy-Marine Corps Resisting Apprehension Conviction?
- When Army Accused Plead Guilty to Resisting Apprehension (another service)
- Pleading Guilty to Article 87a in the Air Force: What Sentences Followed? (another service)
- Guilty Pleas in Navy-Marine Corps AWOL Cases: How Often, and What Came Next
- Search every case in Military Trial Results (members)
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.