NewKnow Your Judge: the court-martial record of 294 military judges → NewLearn Your Lawyer: the court-martial record of 335 military lawyers →
Where All The Bodies Are Buried
Understanding Trends

Army Indecent Recording And Exposure Cases Against Junior Enlisted (E-1 to E-4): Outcomes and Sentences

The Army tried 32 courts-martial from 2021 through 2025 that charged junior enlisted members (E-1 to E-4) under Article 120c (indecent recording and exposure). 93% of those convicted received a punitive discharge, compared with 88% in all Army Article 120c cases.

Understanding Trends in Military Practice · 5 min read

Trends › By Offense › Article 120c › Junior Enlisted (E-1 to E-4)

Short answer: The Army tried 32 courts-martial from 2021 through 2025 that charged junior enlisted members (E-1 to E-4) under Article 120c (indecent recording and exposure). 93% of those convicted received a punitive discharge, compared with 88% in all Army Article 120c cases. 34% of cases were contested, lower than the 43% in all Army Article 120c cases.

Based on 32 cases · 2021–2025 · Army records · data updated October 24, 2026

Punitive Discharges

25 of 27 convicted enlisted members received a bad-conduct or dishonorable discharge (93%). That is higher than the 88% in all Army Article 120c cases. 9 of those 25 were dishonorable discharges.

For enlisted members, a punitive discharge means a bad-conduct or dishonorable discharge. A sentence without a punitive discharge does not rule out a later administrative separation, which these records do not show.

Cases by Year

The 32 cases were tried from March 2021 through September 2025. The yearly counts were 9 in 2021, 3 in 2022, 6 in 2023, 9 in 2024, and 5 in 2025. In a group this small, a few cases can change a percentage, so the comparisons below are approximate. The comparison group is all Army Article 120c cases in the same years, which also includes NCOs and officers.

How Many Cases Were Contested?

21 accused pleaded guilty and 11 contested at least one charge with a not-guilty or mixed plea. The contested share was 34%, lower than the 43% in all Army Article 120c cases.

Of the 21 guilty pleas, 20 are recorded with a plea agreement and 1 has no entry. Army records say whether an agreement existed, not what it said.

Verdicts in Contested Cases

5 of 11 contested cases that reached a verdict ended in a full acquittal (45%). That rate is slightly higher than the 42% in all Army Article 120c cases. 3 cases ended in a partial acquittal: not guilty of at least one charge but guilty of another. Army results list findings charge by charge, which is why partial acquittals are common.

Members heard 7 of the 11 contested cases (64%). Overall, 22% of cases with the forum listed went to members, all 7 to enlisted panels. The other 25 were judge alone. Guilty pleas usually go to a military judge alone, so the forum split mostly follows the number of contested cases.

Confinement After a Conviction

27 cases ended with a conviction on at least one charge, and 26 of those sentences included confinement (96%). The median confinement was 1 year, the same as the 1 year median in all Army Article 120c cases. A quarter of the sentences were 2.3 years or longer.

12 of 27 convictions (44%) were sentenced to more than one year, about the same as the 46% in all Army Article 120c cases. 30% of convictions here were sentenced to under 6 months, compared with 24% in all Army Article 120c cases. These are adjudged sentences, before any plea-agreement cap, clemency, or appeal. Each sentence covers all charges in the case.

Adjudged confinementConvictionsShare hereShare, all Army Article 120c cases
No confinement14%8%
Under 6 months830%24%
6 months to 1 year622%22%
More than 1 year, under 5 years933%32%
5 years or more311%14%

Court Level

28 of 32 cases were general courts-martial (88%). The rest were special courts-martial. Only a general court-martial can adjudge more than one year of confinement or a dishonorable discharge. A special court-martial is capped at one year and can impose a bad-conduct discharge at most.

Other Charges in the Same Cases

Article 120c was the only charge in 12 of 32 cases. The most common other charges were Article 128 (assault) in 9, Article 120 (sexual assault) in 8, Article 134 (general article) in 8, Article 80 (attempt) in 4, and Article 112a (drug) in 3. A sentence covers every charge, so sentences in cases with sexual assault or assault charges include those convictions too.

Installations With the Most Cases

Fort Hood tried 6 of these cases, Joint Base Lewis-McChord 4, Fort Bliss 4, Fort Wainwright 3, and Wheeler Army Airfield 2. Together these five installations account for 59% of the 32 cases. Larger installations try more cases of every kind, so a high count alone does not mean a base has a problem with this offense.

Law Changes and Gaps in the Data

Article 120c is a covered offense. Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute these offenses. When every guilty finding is for an offense after December 27, 2023, the military judge sets the sentence within new sentencing parameters. These records show trial dates, not offense dates. Trials from 2024 on therefore include cases under both the old and new rules.

Cases resolved by nonjudicial punishment, administrative separation, or no action are not in these records. The records do not describe the evidence or the plea terms.

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 tried 2021–2025 that charged junior enlisted members (E-1 to E-4) under Article 120c (32 cases), compared with every Army Article 120c case.

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.

↑ Top