> ## Content Index
> Fetch the complete content index at: https://www.bodiesburied.com/llms.txt
> Use this file to discover other available public pages before exploring further.

# Guilty Pleas in Navy-Marine Corps Disobeying An Officer Cases: How Often, and What Came Next
- URL: https://www.bodiesburied.com/trends/navy-marine-corps-article-90-plea-2017-2025/
- Published: 2026-10-28T06:33:36.000Z
- Updated: 2026-10-30T08:04:55.000Z
- Description: The records hold 51 Navy and Marine Corps courts-martial from 2017–2025 in which the accused pleaded guilty and the charges included Article 90 (disobeying a superior commissioned officer).
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 90, Navy-Marine Corps

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 90](https://www.bodiesburied.com/trends/article-90-courts-martial/) › Guilty Pleas in Navy-Marine Corps Disobe

**Short answer:** The records hold 51 Navy and Marine Corps courts-martial from 2017–2025 in which the accused pleaded guilty and the charges included Article 90 (disobeying a superior commissioned officer). The median adjudged confinement was 8 months, compared with 6 months in all Navy and Marine Corps guilty pleas. Of 44 convicted enlisted members, 27 received a punitive discharge.

Based on 51 cases · 2017–2025 · Navy and Marine Corps records · data updated October 24, 2026

## Domestic Violence Was Often Charged Too

This post covers only guilty pleas in which Article 90 was part of the case. Only 4 of the 51 cases charged Article 90 by itself. Article 128b (domestic violence, numbered since 2019) and Article 92 (orders violation) were each charged in 15 cases, Article 128 (assault) in 11, Article 112a (drug offenses) in 7, and Article 86 (AWOL) in 6.

The records do not describe the facts, so they cannot show how an order from an officer related to the other charges. Each sentence covers every charge in the case. The figures below describe these combined cases, not the Article 90 charge alone.

## Somewhat Longer Confinement Than Most Pleas

Of 51 convictions, 42 included confinement. The median confinement was 8 months, longer than the 6 months across all Navy and Marine Corps guilty pleas. A quarter of terms were 1.2 years or longer. These are adjudged sentences: the sentences announced at trial, before any plea-agreement cap, clemency, or appeal.

Sentences longer than 1 year were about as common as in guilty pleas generally: 12 of 51 convictions (24%), compared with 21%.

## Sentence Lengths by Band

The band above 1 year and under 5 years held 22% of these convictions, compared with 16% across guilty pleas. Only 1 conviction (2%) carried 5 years or more, compared with 5%.

The lower bands were about the same as across the service. Terms under 6 months were 39% of convictions, compared with 40%. Terms from 6 months to 1 year were 20%, compared with 24%. 9 convictions (18%) had no confinement, compared with 15%.

| Adjudged confinement            | Convictions | Share here | Share, all Navy and Marine Corps guilty pleas in those years |
| ------------------------------- | ----------- | ---------- | ------------------------------------------------------------ |
| No confinement                  | 9           | 18%        | 15%                                                          |
| Under 6 months                  | 20          | 39%        | 40%                                                          |
| 6 months to 1 year              | 10          | 20%        | 24%                                                          |
| More than 1 year, under 5 years | 11          | 22%        | 16%                                                          |
| 5 years or more                 | 1           | 2%         | 5%                                                           |

## Sentences Differed by Court Level

Of the 51 cases, 21 were general courts-martial and 30 were special courts-martial. The general court-martial share was 41%, compared with 37% in all Navy and Marine Corps guilty pleas. A general court-martial can impose any lawful sentence. A special court-martial can impose no more than 1 year of confinement and cannot impose a dishonorable discharge.

The median confinement was 1.3 years at general courts-martial and 3 months at special courts-martial. Every case at both levels was a guilty plea, so this difference is between pleas at different court levels, not between pleas and contested trials. No special court-martial here could impose more than 1 year.

## Discharges After a Guilty Plea

Of 44 convicted enlisted members, 27 received a punitive discharge: 23 bad-conduct discharges and 4 dishonorable discharges. Across all Navy and Marine Corps guilty pleas, 60% of convicted enlisted members received a punitive discharge.

The records list 5 convicted officers or warrant officers, and 0 were dismissed. Dismissal is the officer equivalent of a punitive discharge. A sentence without a punitive discharge does not rule out a later administrative separation, which is not in these records. Only a general court-martial can impose a dishonorable discharge, so the 4 dishonorable discharges here came from the 21 general courts-martial.

## Rank and Location of the Accused

The accused included 38 junior enlisted members (E-1 to E-4), 6 NCOs (E-5 to E-9), and 5 officers or warrant officers. The accused were more junior than in Navy and Marine Corps guilty pleas generally, where 65% were junior enlisted members.

Camp Pendleton, California had the most cases, 14\. Camp Lejeune, North Carolina had 9, Norfolk, Virginia 7, San Diego, California 5, and Great Lakes, Illinois 3\. Together these locations account for 75% of the cases. Larger installations try more cases of every kind.

## Why Most Cases Are From 2021 or Later

The trials run from September 2017 to December 2025: 1 in 2017, 1 in 2018, 2 in 2019, 2 in 2020, 14 in 2021, 10 in 2022, 4 in 2023, 7 in 2024, and 10 in 2025\. Navy and Marine Corps records before December 2020 often omit the plea, and this post counts only records that list one. The low early counts do not show that fewer such cases were tried in those years.

The Military Justice Act of 2016 took effect on January 1, 2019\. Among other changes, it introduced written plea agreements. Since December 28, 2023, special trial counsel decide whether to prosecute covered offenses. Offenses after December 27, 2023 are sentenced within new sentencing parameters. Those later rules depend on offense dates, which the records lack.

## Information the Records Lack

The records give trial dates, not offense dates. They do not describe the evidence or the plea terms. They do not include cases handled by nonjudicial punishment or administrative separation.

For what the offense covers and how it is defended, see [Article 90 on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-90/?ref=bodiesburied.com). Dates and sources for the law changes: [UCMJ change timeline](https://www.bodiesburied.com/trends/ucmj-change-timeline/).

### How We Counted

Navy and Marine Corps courts-martial tried 2017–2025: where the accused pleaded guilty to charges including Article 90 (disobeying an officer) (51 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](https://www.bodiesburied.com/military-trial-results/), data updated October 24, 2026\. Definitions, sources, and known gaps: [how this data was built](https://www.bodiesburied.com/trends/how-the-military-trial-results-data-was-built/). Errors: content@bodiesburied.com.

## Related Analysis

- [Article 90 (Willfully Disobeying Superior Officer): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-90-courts-martial/) (hub)
- [Sentences](https://www.bodiesburied.com/trends/sentences/) (hub)
- [Fewer or More? Disobeying An Officer Charges at Navy-Marine Corps Courts-Martial, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-90-trend-2017-2025/)
- [What Sentence Follows a Navy-Marine Corps Disobeying an Officer Conviction?](https://www.bodiesburied.com/trends/navy-marine-corps-article-90-sent-2017-2025/)
- [Fighting a Navy-Marine Corps Disobeying An Officer Charge: How Contested Cases Ended](https://www.bodiesburied.com/trends/navy-marine-corps-article-90-acq-2017-2025/)
- [Pleading Guilty to Article 90 in the Army: What Sentences Followed?](https://www.bodiesburied.com/trends/army-article-90-plea-2021-2025/) (another service)
- [Guilty Pleas in Air Force Disobeying An Officer Cases: How Often, and What Came Next](https://www.bodiesburied.com/trends/air-force-article-90-plea-2016-2025/) (another service)
- [Article 90 explained on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-90/?ref=bodiesburied.com)
- [Search every case in Military Trial Results](https://www.bodiesburied.com/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](https://www.ucmj-defender.com/?ref=bodiesburied.com). This analysis is for education and information only. It is not legal advice, and every case is different.