Did Obstruction Cases at San Diego, California Change After 2019?
San Diego, California had 17 courts-martial charging Article 131b (obstruction) in 2019–2023.
Understanding Trends in Military Practice · 5 min read
Trends › By Installation › San Diego, California › Article 131b
Short answer: San Diego, California had 17 courts-martial charging Article 131b (obstruction) in 2019–2023. A punitive discharge followed 56% of enlisted convictions, lower than the 82% in all Navy and Marine Corps Article 131b cases, and the median confinement was 6 months, compared with 10 months service-wide. Junior enlisted members made up 81% of the accused.
Punitive Discharges Less Often Than Service-Wide
A punitive discharge followed 56% of enlisted convictions: 7 bad-conduct discharges and 2 dishonorable discharges. In all Navy and Marine Corps Article 131b cases in 2019–2023, the share was 82%.
A sentence without a punitive discharge does not rule out a later administrative separation, which these records do not cover.
Shorter Confinement
All 17 cases ended in a conviction on at least one charge, and 16 of those sentences included confinement (94%). The median confinement was 6 months, shorter than the 10 months median in all Navy and Marine Corps Article 131b cases. Among the sentences that included confinement, a quarter were 10 months or longer.
These are adjudged sentences, before any plea-agreement cap, clemency, or appeal. Each covers every charge in the case.
Obstruction Was Almost Never Charged Alone
Of the 17 cases, 16 charged at least one other article. Article 92 (orders violation) was charged in 5 cases and Article 134 (general article) in 4. Article 128 (assault) and Article 107 (false official statement) were each charged in 3, and Article 121 (larceny) in 2.
Mostly Junior Enlisted Accused
Junior enlisted members (E-1 to E-4) made up 81% of the accused, NCOs 19%, and officers 0%. In all Navy and Marine Corps Article 131b cases in 2019–2023, junior enlisted members were 68%.
General courts-martial heard 7 of the 17 cases (41%), compared with 47% service-wide. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge.
Guilty Pleas in Most Cases
Of 17 cases with a plea recorded, 14 had a guilty plea and 3 had a not-guilty or mixed plea. A case is contested when the accused pleads not guilty to at least one charge. The contested share was 18%, compared with 26% in all Navy and Marine Corps Article 131b cases. None of the 3 contested cases ended in a full acquittal.
Before and After 2019
Obstruction has been numbered Article 131b since 2019. The comparison period, 2013–2018, had 12 such cases over the 5 years with cases on record, about 2 a year. Since 2019 there have been about 3 a year: 6 in 2019, 2 in 2020, 3 in 2021, 2 in 2022, and 4 in 2023. These 17 cases were 10% of the 173 courts-martial at San Diego in 2019–2023.
Punitive discharges for convicted enlisted members went from 33% to 56%. Convictions with confinement went from 75% to 94%, and the median confinement went from 4 months to 6 months. General courts-martial went from 25% to 41%. Both groups are small, so the changes show a direction only.
| 2013–2018 | 2019–2023 | |
|---|---|---|
| Cases | 12 | 17 |
| Contested (of pleas recorded) | 27% | 18% |
| Full acquittals (decided contested) | 0 of 3 | 0 of 3 |
| Convictions with confinement | 75% | 94% |
| Median confinement | 4 months | 6 months |
| Punitive discharge (enlisted) | 33% | 56% |
| General courts-martial | 25% | 41% |
What the Records Cannot Show
The records cover only cases that reached a courtroom, not nonjudicial punishment, administrative separations, or cases with no action. They do not describe the evidence or the plea terms. Navy and Marine Corps records before December 2020 often omit the plea.
Dates and sources for the law changes mentioned here: UCMJ change timeline.
How We Counted
Courts-martial tried at San Diego, California that charged Article 131b (found guilty, not guilty, or both): 2013–2018 (12) and 2019–2023 (17). Comparisons use every Navy and Marine Corps case charging Article 131b in 2019–2023.
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 (the whole docket)
- Inside 173 Courts-Martial at San Diego, California, 2019–2023 (the whole docket)
- San Diego, California Courts-Martial, 2024–2026: What 126 Cases Show (the whole docket)
- Is Navy-Marine Corps Obstruction Prosecution Rising or Falling? Article 131b, 2017–2025
- Article 107 at Camp Lejeune, North Carolina Before and After 2019
- Article 112a at Camp Pendleton, California Before and After 2019
- Article 112a at Camp Pendleton, California Before and After 2024
- 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.