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# Fewer or More? Disobeying An Officer Charges at Navy-Marine Corps Courts-Martial, 2017–2025
- URL: https://www.bodiesburied.com/trends/navy-marine-corps-article-90-trend-2017-2025/
- Published: 2026-10-28T08:05:20.000Z
- Updated: 2026-10-30T05:10:48.000Z
- Description: Article 90 (disobeying an officer) was part of 2% of Navy and Marine Corps convictions in 2017–2019 and 4% in 2023–2025, a larger share.
- 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/) › Navy-Marine Corps

**Short answer:** Article 90 (disobeying an officer) was part of 2% of Navy and Marine Corps convictions in 2017–2019 and 4% in 2023–2025, a larger share. Across 109 cases from 2017–2025, only 1 of 27 contested cases that reached a verdict (4%) ended in a full acquittal, compared with 31% across the service. Of convicted enlisted members, 58% received a punitive discharge, compared with 62%.

Based on 109 cases · 2017–2025 · Navy and Marine Corps records · data updated October 24, 2026

## Few Full Acquittals

Of 27 contested cases that reached a verdict, 1 ended in a full acquittal (4%). Across all Navy and Marine Corps cases in those years, the full acquittal rate was 31%.

Partial acquittals were more common. Another 12 cases ended with a not-guilty finding on at least one charge or specification and a guilty finding on another. In all, 107 of the 109 cases ended in a conviction on at least one charge.

## A Larger Share of Convictions

In 2017–2019, Article 90 appeared in 26 of 1243 Navy and Marine Corps convictions with offenses listed, a 2% share. In 2023–2025 it appeared in 35 of 940, or 4%. The share was larger in the later period, while the total number of convictions was smaller.

The yearly counts went up and down. Convictions including the charge numbered 13 in 2017 and 6 in 2018\. The highest count was 18 in 2021 (5% of that year's convictions). There were 5 in 2023, 14 in 2024, and 16 in 2025\. The 2025 share was 5%, the same as in 2021.

| Year | Convictions incl. Art. 90 | All convictions with offenses listed | Share |
| ---- | ------------------------- | ------------------------------------ | ----- |
| 2017 | 13                        | 437                                  | 3%    |
| 2018 | 6                         | 433                                  | 1%    |
| 2019 | 7                         | 373                                  | 2%    |
| 2020 | 13                        | 354                                  | 4%    |
| 2021 | 18                        | 385                                  | 5%    |
| 2022 | 15                        | 322                                  | 5%    |
| 2023 | 5                         | 283                                  | 2%    |
| 2024 | 14                        | 345                                  | 4%    |
| 2025 | 16                        | 312                                  | 5%    |

## Cases Tried Each Year

Counted by case rather than by conviction, the data holds 109 Article 90 courts-martial from January 2017 to December 2025\. The yearly counts from 2017 through 2025 were 13, 6, 8, 13, 19, 15, 5, 14, and 16\. These cases are 3% of the 3,740 Navy and Marine Corps courts-martial in the period.

Navy and Marine Corps convictions that included Article 90, by year: 2017 13, 2018 6, 2019 7, 2020 13, 2021 18, 2022 15, 2023 5, 2024 14, 2025 16132017620187201913202018202115202252023142024162025

Navy and Marine Corps convictions that included Article 90, by year

## Most Accused Pleaded Guilty

A case is contested when the accused pleads not guilty to at least one charge, either to every charge or as a mixed plea. Of the 109 records, 78 list a plea: 51 were guilty pleas and 27 were contested. The contested share was 35%, close to the 32% for the Navy and Marine Corps as a whole.

The contested share was about the same at both court levels: 36% at general courts-martial and 33% at special courts-martial.

## Confinement by Court Level

Of 107 convictions, 82 included confinement (77%). The median confinement was 7 months, close to the 6 months for the rest of the Navy and Marine Corps. These are adjudged sentences, announced at trial before any plea-agreement cap, clemency, or appeal. Each covers every charge in the case.

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 1.1 years at the 44 general courts-martial and 3 months at the 65 special courts-martial. General courts-martial were 40% of these cases.

Terms longer than 1 year were in 20 of 107 convictions (19%), compared with 25% elsewhere in the Navy and Marine Corps. Only 2 sentences (2%) were 5 years or more, compared with 7%.

| Adjudged confinement            | Convictions | Share here | Share, the Navy and Marine Corps as a whole |
| ------------------------------- | ----------- | ---------- | ------------------------------------------- |
| No confinement                  | 25          | 23%        | 18%                                         |
| Under 6 months                  | 35          | 33%        | 35%                                         |
| 6 months to 1 year              | 27          | 25%        | 22%                                         |
| More than 1 year, under 5 years | 18          | 17%        | 18%                                         |
| 5 years or more                 | 2           | 2%         | 7%                                          |

## Discharges for Enlisted Members

Of 99 convicted enlisted members, 57 received a bad-conduct or dishonorable discharge (58%). Across the Navy and Marine Corps, the figure was 62%. Of those 57, 7 were dishonorable. The data shows 5 convicted officers or warrant officers, and none was dismissed. Dismissal is the officer form of a punitive discharge. A member sentenced without a punitive discharge can still face administrative separation.

## Who Was Charged, and Where

Among the accused with rank recorded, 74 were junior enlisted members (E-1 to E-4), 26 were NCOs (E-5 to E-9), and 5 were officers or warrant officers. The accused were more junior than across all Navy and Marine Corps cases, where 63% were junior enlisted members.

Of the 109 cases, 100 included another article. The most common were Article 92 (orders violation) in 36 cases, Article 128 (assault) in 32, Article 128b (domestic violence, numbered since 2019) in 23, Article 134 (general article) in 20, and Article 112a (drug) in 16.

Camp Pendleton, California tried 30 of these cases, Camp Lejeune, North Carolina 22, Norfolk, Virginia 11, San Diego, California 7, and MCAS Miramar, California 6\. Together these locations account for 70% of the total. Large installations try more cases of all kinds.

## Law Changes and Missing Information

The Military Justice Act of 2016 took effect on January 1, 2019\. It added judge-alone special courts-martial and written plea agreements. Since December 28, 2023, special trial counsel decide whether to prosecute covered offenses. Judges sentence within new parameters for offenses after December 27, 2023\. Article 90's share of convictions was larger in the same period, but the records cannot show whether any law change caused it.

The records list trial dates, not offense dates. They do not describe the evidence or plea terms. Nonjudicial punishment and administrative separations are not included, and Navy and Marine Corps records before December 2020 often omit the plea.

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 that charged Article 90 (109 cases). The trend line uses convictions whose records list the offenses found, by trial year.

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)
- [Navy-Marine Corps Courts-Martial: Data and Trends](https://www.bodiesburied.com/trends/navy-marine-corps-courts-martial/) (hub)
- [By Offense](https://www.bodiesburied.com/trends/by-offense/) (hub)
- [Is Army Disobeying An Officer Prosecution Rising or Falling? Article 90, 2021–2025](https://www.bodiesburied.com/trends/army-article-90-trend-2021-2025/) (another service)
- [Air Force Article 90 Cases by the Numbers, 2016–2025](https://www.bodiesburied.com/trends/air-force-article-90-trend-2016-2025/) (another service)
- [Fewer or More? Attempt Charges at Navy-Marine Corps Courts-Martial, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-80-trend-2017-2025/)
- [Fewer or More? Child Endangerment Charges at Navy-Marine Corps Courts-Martial, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-119b-trend-2017-2025/)
- [Fewer or More? Child Sexual Abuse Charges at Navy-Marine Corps Courts-Martial, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-120b-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/)
- [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.