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What Happens to Navy-Marine Corps Junior Enlisted (E-1 to E-4) Facing Disobeying An Officer Charges?

Junior enlisted members (E-1 to E-4) were charged under Article 90 (disobeying an officer) in 74 Navy and Marine Corps courts-martial from 2017–2025. Of those convicted, 68% received a punitive discharge, compared with 58% across all Navy and Marine Corps Article 90 cases.

Understanding Trends in Military Practice · 5 min read

Trends › By Offense › Article 90 › Junior Enlisted (E-1 to E-4)

Short answer: Junior enlisted members (E-1 to E-4) were charged under Article 90 (disobeying an officer) in 74 Navy and Marine Corps courts-martial from 2017–2025. Of those convicted, 68% received a punitive discharge, compared with 58% across all Navy and Marine Corps Article 90 cases. The median confinement was 8 months, compared with 7 months in the wider group.

Based on 74 cases · 2017–2025 · Navy and Marine Corps records · data updated October 24, 2026

Assault and Domestic Violence Were Often Charged Too

Article 90 was the only charge in 4 of the 74 cases, compared with 9 of 109 across the service. The most common other charge was Article 128 (assault), in 25 cases.

Article 92 (orders violation) was charged in 18 cases, Article 128b (domestic violence, numbered since 2019) in 16, Article 112a (drug) in 15, and Article 134 (general article) in 13. Each sentence covers all of the charges in its case, so the figures below describe the full cases.

Punitive Discharges Were More Common

Of 73 convicted members, 50 received a bad-conduct or dishonorable discharge. That is 68%, higher than the 58% for all Navy and Marine Corps Article 90 cases. Only 6 of the discharges were dishonorable.

A member whose sentence did not include a punitive discharge could still face administrative separation. These court records do not show administrative separations.

Most Confinement Terms Were Under 1 Year

Confinement was part of 66 of the 73 sentences (90%). The median confinement was 8 months, slightly longer than the 7-month median across the service. A quarter of terms were 1 year or longer.

Fewer convictions here had no confinement than in the wider group: 10% compared with 23%. More were in the 6 months to 1 year band: 37% compared with 25%. The under-6-months band was about the same: 34% compared with 33%.

Terms over 1 year were in 14 of 73 convictions (19%), the same as the 19% for all Navy and Marine Corps Article 90 cases. These are adjudged sentences, before any plea-agreement cap, clemency, or appeal.

Adjudged confinementConvictionsShare hereShare, all Navy and Marine Corps Article 90 cases
No confinement710%23%
Under 6 months2534%33%
6 months to 1 year2737%25%
More than 1 year, under 5 years1318%17%
5 years or more11%2%

Fewer Cases Were Contested

Of the 74 records, 52 show a plea. Of those, 38 were guilty pleas and 14 were contested. A contested case is one with a not-guilty plea to at least one charge, including mixed pleas.

The contested share was 27%, lower than the 35% for the service's Article 90 cases. Navy and Marine Corps records before December 2020 often omit the plea, so these shares use only the records that include it.

How Contested Cases Ended

Of the 14 contested cases that reached a verdict, 7% ended in a full acquittal, compared with 4% across the service. Partial acquittals were more common: 6 cases ended with a not-guilty finding on at least one charge or specification and a conviction on another. In all, 73 of the 74 cases ended with a conviction on at least one charge.

General and Special Courts-Martial

General courts-martial were 45% of these cases (33 of 74), and special courts-martial tried the other 41. Only a general court-martial can impose more than 1 year of confinement or a dishonorable discharge.

The median confinement was 1 year at general courts-martial and 3 months at special courts-martial. The contested share was 32% at general courts-martial and 22% at special courts-martial.

Year by Year

There were 11 cases in 2017 and 5 in each of 2018, 2019, and 2020. There were 16 cases in 2021, 12 in 2022, 4 in 2023, 7 in 2024, and 9 in 2025.

The 16 cases in 2021 were the most in any year. The records run from January 2017 to December 2025. With counts this small, a change of a few cases from one year to the next does not show a trend on its own.

Share of Cases and Installations

Junior enlisted members were 70% of the accused across all Navy and Marine Corps Article 90 cases. These 74 cases are most of the service's cases for disobeying an officer.

Camp Pendleton, California tried 25 of the cases and Camp Lejeune, North Carolina tried 18. Norfolk, Virginia tried 8, San Diego, California 4, and Quantico, Virginia 3. These 5 locations account for 78% of the 74. Larger installations try more cases of every kind, so a count alone does not single out a base.

Rules in Effect and Gaps in the Data

The Military Justice Act of 2016 took effect on January 1, 2019. Since December 28, 2023, special trial counsel decide whether to prosecute covered offenses such as domestic violence, which was charged in 16 of these cases. New sentencing parameters apply when every guilty finding is for an offense after December 27, 2023. The records have trial dates but not offense dates.

Nonjudicial punishment, administrative separations, the evidence, and plea terms are not in these records.

For what the offense covers and how it is defended, see Article 90 on the law firm's website. Dates and sources for the law changes: UCMJ change timeline.

How We Counted

Navy and Marine Corps courts-martial tried 2017–2025 that charged junior enlisted members (E-1 to E-4) under Article 90 (74 cases), compared with every Navy and Marine Corps Article 90 case.

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.

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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