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Understanding Trends

Army Courts-Martial With Article 120c and Article 134, 2021–2025

The records hold 12 Army courts-martial from 2021–2025 that charged both indecent recording or exposure under Article 120c and the general article, Article 134. The 11 convictions all carried confinement, with a median of 2 years, compared with 1 year for all Army Article 120c cases.

Understanding Trends in Military Practice · 4 min read

Trends › By Offense › Article 120c › Army, with Article 134

Short answer: The records hold 12 Army courts-martial from 2021–2025 that charged both indecent recording or exposure under Article 120c and the general article, Article 134. The 11 convictions all carried confinement, with a median of 2 years, compared with 1 year for all Army Article 120c cases.

Based on 12 cases · 2021–2025 · Army records · data updated October 24, 2026

A Median of 2 Years of Confinement

11 cases ended in a conviction on at least one charge, and all 11 sentences included confinement (100%). The median confinement was 2 years, longer than the 1 year median in all Army Article 120c cases in 2021–2025. A quarter of the sentences were 3.3 years or longer.

The figures are adjudged sentences. They reflect the sentence at trial, before any plea-agreement cap, clemency, or appeal, and they cover every charge in the case.

Every Convicted Enlisted Member Received a Punitive Discharge

A punitive discharge followed 100% of enlisted convictions: 7 dishonorable discharges and 3 bad-conduct discharges. Army-wide Article 120c cases had a rate of 88%.

1 convicted officer or warrant officer appears and was dismissed, the officer form of a punitive discharge. A sentence without a punitive discharge does not rule out a later administrative separation.

An Even Split on Pleas

6 accused pleaded guilty and 6 contested at least one charge. A contested case is one with a not-guilty or mixed plea. The contested share was 50%, compared with 40% in Army-wide Article 120c cases.

Companion Charges

None of the 12 cases charged Article 120c alone. In all Army Article 120c cases in 2021–2025, 19 of 70 did. Besides Article 134, Article 120, sexual assault, appeared in 5 cases. Article 128, assault; Article 80, attempt; and Article 112a, drug offenses, each appeared in 3.

Who Decided Guilt?

A military judge alone decided 9 cases. Members heard 25% of the cases with the forum listed: 2 enlisted panels and 1 officer panel. The accused usually chooses whether a military judge alone or a panel of members decides guilt.

Rank of the Accused

Junior enlisted members (E-1 to E-4) made up 67% of the accused, NCOs 25%, and officers 8%. Across Army-wide Article 120c cases, junior enlisted members were 54%, so this group was more junior.

Trial Years

The trials ran from April 2021 to January 2025: 5 in 2021, 0 in 2022, 1 in 2023, 5 in 2024, and 1 in 2025. Army records in this data are sparse before 2021.

What the Records Cannot Tell

Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute covered offenses such as sexual assault, domestic violence, and murder. When every guilty finding is for an offense after December 27, 2023, the military judge sets the sentence within new sentencing parameters. The records give trial dates, not offense dates, so the 2024 and 2025 trials could fall under either set of rules.

The records do not show the evidence, the plea terms, or conduct handled outside a court-martial, and they do not report the court level for this group.

For what the offense covers and how it is defended, see Article 120c on the law firm's website. Dates and sources for the law changes: UCMJ change timeline.

How We Counted

Army courts-martial with trial dates in 2021–2025 that charged both Article 120c and Article 134 (12 cases), compared with all 70 Army Article 120c cases 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.

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.

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