Article 131b Cases at San Diego, California, 2019–2023: 17 Courts-Martial
From 2019 through 2023, San Diego, California had 17 courts-martial charging Article 131b (obstruction, numbered since 2019). 16 of the 17 convictions included confinement, with a median of 6 months, compared with 10 months across all Navy and Marine Corps Article 131b cases.
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Trends › By Installation › San Diego, California › Article 131b, 2019–2023
Short answer: From 2019 through 2023, San Diego, California had 17 courts-martial charging Article 131b (obstruction, numbered since 2019). 16 of the 17 convictions included confinement, with a median of 6 months, compared with 10 months across all Navy and Marine Corps Article 131b cases. 56% of convicted enlisted members received a punitive discharge, lower than the 82% service figure.
Confinement in Nearly Every Sentence
Every one of the 17 cases ended in a conviction on at least one charge. Confinement was part of 16 of those sentences (94%). The median confinement was 6 months. In all Navy and Marine Corps Article 131b cases in 2019–2023, the median was 10 months.
Among the sentences that included confinement, a quarter were 10 months or longer. All of these are adjudged sentences, before any plea-agreement cap, clemency, or appeal. A sentence covers every charge in the case, so it reflects more than the obstruction count.
Bad-Conduct and Dishonorable Discharges
Of 16 enlisted members convicted, 9 received a bad-conduct or dishonorable discharge (56%). 2 of those 9 were dishonorable discharges. Navy and Marine Corps-wide, 82% of convicted enlisted members in Article 131b cases received a punitive discharge.
The members who did not receive a punitive discharge could still face an administrative separation later. Those separations are outside these records.
A Younger Group of Accused
Junior enlisted members (E-1 to E-4) were 81% of the accused. NCOs were 19%, and there were no officers. Across Navy and Marine Corps-wide Article 131b cases, junior enlisted members were 68% of the accused.
Guilty Pleas in Most Cases
14 accused pleaded guilty. 3 entered a not-guilty or mixed plea, which makes a case contested. The contested share was 18% of cases with a plea recorded, compared with 26% in Navy and Marine Corps-wide Article 131b cases. Navy and Marine Corps records before December 2020 often omit the plea, so these counts use only the records that list it.
General or Special Court-Martial
7 of the 17 cases went to a general court-martial (41%). The share in Navy and Marine Corps Article 131b cases overall was 47%. The rest were special courts-martial. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge.
Charges Filed With Obstruction
16 of the 17 cases charged at least one other article. The most common were Article 92 (orders violation) in 5 cases and Article 134 (general article) in 4. Article 128 (assault) and Article 107 (false official statement) each appeared in 3. Article 121 (larceny) appeared in 2.
Cases by Year
The first of these trials was in March 2019 and the last in December 2023. There were 6 in 2019, 2 in 2020, 3 in 2021, 2 in 2022, and 4 in 2023. Together they were 10% of the 173 courts-martial at San Diego, California in 2019–2023.
What Is Not in the Data
Trial records do not describe the evidence or the plea terms. They give the trial date, not the date of the offense. Cases resolved by nonjudicial punishment or administrative separation do not appear at all.
Dates and sources for the law changes mentioned here: UCMJ change timeline.
How We Counted
Courts-martial tried at San Diego, California in 2019–2023 that charged Article 131b (17 cases), compared with every Navy and Marine Corps case charging Article 131b 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
- San Diego, California: Court-Martial Data and Trends (hub)
- Article 131b (Obstruction, Numbered Since 2019): Court-Martial Data and Trends (hub)
- By Installation (hub)
- San Diego, California Courts-Martial, 2013–2018: What 285 Cases Show
- Inside 173 Courts-Martial at San Diego, California, 2019–2023
- San Diego, California Courts-Martial, 2024–2026: What 126 Cases Show
- Did Obstruction Cases at San Diego, California Change After 2019?
- Is Navy-Marine Corps Obstruction Prosecution Rising or Falling? Article 131b, 2017–2025
- Search every case in Military Trial Results (members)
Military Judges Who Presided Over Article 131b Cases at San Diego, California, 2019–2023
Names and links only. Each judge's record of pleas, findings, and sentences is on their Know Your Judge page, part of the Court-Martial Characters membership.
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.