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# Not Guilty Pleas in Army Article 120c Cases: What Happened at Trial
- URL: https://www.bodiesburied.com/trends/army-article-120c-acq-2021-2025/
- Published: 2026-10-28T08:06:30.000Z
- Updated: 2026-10-30T08:04:56.000Z
- Description: 11 of 26 contested Army cases charging Article 120c (indecent recording and exposure) from 2021 through 2025 ended in a full acquittal (42%). That is slightly higher than the 38% in all contested Army cases.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 120c, Army

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 120c](https://www.bodiesburied.com/trends/article-120c-courts-martial/) › Not Guilty Pleas in Army Article 120c Ca

**Short answer:** 11 of 26 contested Army cases charging Article 120c (indecent recording and exposure) from 2021 through 2025 ended in a full acquittal (42%). That is slightly higher than the 38% in all contested Army cases. 77% of convicted enlisted members received a punitive discharge, compared with 64%. The median confinement was 1.2 years, compared with 1.5 years.

Based on 26 cases · 2021–2025 · Army records · data updated October 24, 2026

## More Full Acquittals Than in Other Contested Cases

Article 120c covers offenses such as indecent recording and indecent exposure. Between February 2021 and April 2025, the Army records show 26 courts-martial in which the accused contested a charge under it. A contested case is one with a not-guilty or mixed plea. None of these cases was a guilty plea.

11 of those 26 cases ended in a full acquittal (42%). That rate is higher than the 38% in all contested Army cases in those years. 10 cases (38%) ended in a partial acquittal: not guilty of at least one charge or specification but guilty of another. Army results list findings charge by charge, which is why partial acquittals are common in Army data.

## Full Acquittals by Who Decided Guilt

Contested cases decided by members ended in a full acquittal 62% of the time (8 of 13). Contested cases decided by a military judge alone ended in a full acquittal 17% of the time (2 of 12). These 25 cases are the decided contested cases with the forum listed.

Members heard 13 cases (52%): 12 enlisted panels and 1 officer panel. A military judge alone decided 12 (48%). The accused usually chooses the forum, so the cases each one heard are not alike. The counts are too small to show a stable pattern.

## Often Charged With Sexual Assault

Article 120c was the only charge in 5 of 26 cases. Article 120 (sexual assault) was also charged in 13, Article 128 (assault) in 9, Article 80 (attempt) and Article 134 (general article) in 6 each, and Article 92 (orders violation) in 4.

An adjudged sentence covers every charge in the case. A long sentence here may include a sexual assault conviction, not only the recording or exposure charge.

## Confinement After a Conviction

87% of the 15 convictions included confinement. The median confinement was 1.2 years, compared with 1.5 years in all contested Army cases. A quarter of the sentences were 2.3 years or longer. The records include 1 life sentence among these convictions, and that sentence covers the whole case, not a single charge.

These are adjudged sentences, before any plea-agreement cap, clemency, or appeal. With only 15 convictions, a few long or short sentences can change the median. The comparison with the Army-wide figure is approximate.

## Punitive Discharges and Dismissals

10 of 13 convicted enlisted members received a punitive discharge: 5 bad-conduct discharges and 5 dishonorable discharges. The share in all contested Army cases was 64%.

2 officers or warrant officers were convicted, and both 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.

## Court Level and Rank

General courts-martial, the level that can impose long confinement and a dishonorable discharge, made up 92% of these cases (24 of 26). The rest were special courts-martial, which cap confinement at one year.

The accused were 11 junior enlisted members (E-1 to E-4), 13 NCOs (E-5 to E-9), and 2 officers or warrant officers. That mix is similar to all contested Army cases, where 44% were junior enlisted.

## Cases by Year and Installation

The yearly counts were 5 in 2021, 6 in 2022, 6 in 2023, 5 in 2024, and 4 in 2025\. Fort Hood had the most cases, 5\. Fort Carson and Joint Base Lewis-McChord had 3 each, and Fort Wainwright and Fort Campbell 2 each. Together these installations account for 58% of the 26 cases. Larger installations try more cases of every kind.

No single year or installation had most of the cases. The records give trial dates, not offense dates. A case tried in 2025 may involve conduct from earlier years. The yearly counts do not show how often these offenses occurred.

## Covered-Offense Rules and Missing Details

Article 120c is a covered offense. Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute covered offenses. When every guilty finding is for an offense after December 27, 2023, the military judge sets the sentence within new sentencing parameters. Both changes depend on offense dates, and the records list only trial dates. Trials in 2024 and 2025 therefore include old-rule and new-rule cases.

The records do not describe the evidence or the plea terms. Cases handled by nonjudicial punishment or administrative separation do not appear in them.

For what the offense covers and how it is defended, see [Article 120c on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-120c/?ref=bodiesburied.com). Dates and sources for the law changes: [UCMJ change timeline](https://www.bodiesburied.com/trends/ucmj-change-timeline/).

### How We Counted

Army courts-martial tried 2021–2025: where the accused contested a charge under Article 120c (indecent recording and exposure) (26 cases), compared with all contested Army cases 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 120c (Other Sexual Misconduct): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-120c-courts-martial/) (hub)
- [By Offense](https://www.bodiesburied.com/trends/by-offense/) (hub)
- [Fewer or More? Indecent Recording And Exposure Charges at Army Courts-Martial, 2021–2025](https://www.bodiesburied.com/trends/army-article-120c-trend-2021-2025/)
- [Article 120c Sentences in the Army: Confinement and Discharges, 2021–2025](https://www.bodiesburied.com/trends/army-article-120c-sent-2021-2025/)
- [When Army Accused Plead Guilty to Indecent Recording And Exposure](https://www.bodiesburied.com/trends/army-article-120c-plea-2021-2025/)
- [Not Guilty Pleas in Navy-Marine Corps Article 120c Cases: What Happened at Trial](https://www.bodiesburied.com/trends/navy-marine-corps-article-120c-acq-2017-2025/) (another service)
- [Fighting an Army Child Endangerment Charge: How Contested Cases Ended](https://www.bodiesburied.com/trends/army-article-119b-acq-2021-2025/)
- [Fighting an Army Communicating Threats Charge: How Contested Cases Ended](https://www.bodiesburied.com/trends/army-article-115-acq-2021-2025/)
- [Article 120c explained on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-120c/?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.