> ## Content Index
> Fetch the complete content index at: https://www.bodiesburied.com/llms.txt
> Use this file to discover other available public pages before exploring further.

# Fewer or More? Indecent Recording And Exposure Charges at Army Courts-Martial, 2021–2025
- URL: https://www.bodiesburied.com/trends/army-article-120c-trend-2021-2025/
- Published: 2026-10-28T06:33:05.000Z
- Updated: 2026-10-30T08:04:05.000Z
- Description: From 2021 through 2025, 61 Army courts-martial charged Article 120c (indecent recording and exposure). Its share of Army convictions was between 1% and 3% each year.
- 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/) › Army

**Short answer:** From 2021 through 2025, 61 Army courts-martial charged Article 120c (indecent recording and exposure). Its share of Army convictions was between 1% and 3% each year. The median confinement was 1 year, compared with 6 months across the Army, and 88% of convicted enlisted members received a punitive discharge, compared with 73% in the rest of the Army.

Based on 61 cases · 2021–2025 · Army records · data updated October 24, 2026

## Is the Share Rising or Falling?

Article 120c covers offenses such as indecent recording, broadcasting, and exposure. Of Army convictions with offenses listed, the share that included Article 120c was 2% in 2021, 1% in 2022, 2% in 2023, 3% in 2024, and 2% in 2025.

The number of convictions that included the article was 11, 4, 7, 13, and 8 in those years. The highest was 13, in 2024\. The number of cases was 15, 9, 12, 16, and 9\. In all, these cases are 3% of the 2,422 Army courts-martial in the period. Shares of convictions allow a comparison across years with more or fewer cases overall.

| Year | Convictions incl. Art. 120c | All convictions with offenses listed | Share |
| ---- | --------------------------- | ------------------------------------ | ----- |
| 2021 | 11                          | 467                                  | 2%    |
| 2022 | 4                           | 424                                  | 1%    |
| 2023 | 7                           | 408                                  | 2%    |
| 2024 | 13                          | 428                                  | 3%    |
| 2025 | 8                           | 388                                  | 2%    |

## Yearly Convictions in One View

Convictions that included Article 120c were lowest in 2022, at 4, and highest in 2024, at 13\. In 2021–2022 the article was part of 15 of 891 Army convictions (2%), and in 2024–2025 it was part of 21 of 816 (3%), about the same share.

Army convictions that included Article 120c, by year: 2021 11, 2022 4, 2023 7, 2024 13, 2025 8112021420227202313202482025

Army convictions that included Article 120c, by year

## Confinement After a Conviction

92% of the 50 convictions included confinement. The median confinement was 1 year, compared with 6 months across the Army. A quarter of the sentences were 2.5 years or longer. The convictions included 1 life sentence.

23 of 50 convictions (46%) included more than one year of confinement, compared with 28% across the Army. Sentences of more than 1 year but under 5 years made up 32% of convictions, compared with 20% Army-wide. Sentences of 5 years or more made up 14%, compared with 8%. 8% of convictions had no confinement, compared with 17% across the Army. The figures are adjudged sentences, before any plea-agreement cap, clemency, or appeal, and each one covers every charge in its case.

| Adjudged confinement            | Convictions | Share here | Share, the whole Army docket |
| ------------------------------- | ----------- | ---------- | ---------------------------- |
| No confinement                  | 4           | 8%         | 17%                          |
| Under 6 months                  | 12          | 24%        | 39%                          |
| 6 months to 1 year              | 11          | 22%        | 16%                          |
| More than 1 year, under 5 years | 16          | 32%        | 20%                          |
| 5 years or more                 | 7           | 14%        | 8%                           |

## Other Charges in the Same Cases

Article 120c was the only charge in 14 of the 61 cases. The most common other charge was Article 120 (sexual assault), in 18 cases. Article 80 (attempt) and Article 128 (assault) were each charged in 14, Article 134 (general article) in 12, and Article 92 (orders violation) in 5.

The sentences above therefore include convictions for these other charges, not Article 120c alone. 53 of the 61 cases (87%) were general courts-martial, which can impose any lawful sentence. Across the Army, the share was 73%.

## More Cases Were Contested

Of the 61 accused, 35 pleaded guilty and 26 contested at least one charge with a not-guilty or mixed plea. The contested share was 43%, higher than the 30% across the Army.

Of the 35 guilty pleas, 32 are recorded with a plea agreement and 3 have no entry. Army records say whether an agreement existed, not what it said.

## Members Acquitted More Often Than Judges

42% of the 26 contested cases that reached a verdict ended in a full acquittal. That is higher than the 38% in the rest of the Army. 10 ended in a partial acquittal: not guilty of at least one charge or specification, guilty of another. Army results list findings charge by charge.

Members returned a full acquittal in 8 of 13 contested cases (62%). A military judge alone returned a full acquittal in 2 of 12 (17%). Members heard 13 of 25 contested cases (52%): 12 enlisted panels and 1 officer panel. Overall, a military judge alone decided 47 of 60 cases (78%). The accused usually chooses the forum, so these groups of cases are not alike.

## Discharges and Dismissals

37 of 42 convicted enlisted members received a bad-conduct or dishonorable discharge (88%), compared with 73% Army-wide. 13 of those were dishonorable discharges. 5 of 7 convicted officers or warrant officers were dismissed. A later administrative separation is still possible when a sentence has no punitive discharge.

By rank, the accused were 32 junior enlisted members, 21 NCOs, and 7 officers. That mix is similar to the Army as a whole.

## Where Were the Cases Tried?

Fort Hood (12), Joint Base Lewis-McChord (8), Fort Bliss (5), Fort Knox (5), and Fort Stewart (4) tried the most of these cases. Together they account for 56% of the 61 cases. Larger installations try more cases of every kind, so these counts do not show a problem at any one base.

## Law Changes and What the Records Do Not Show

Article 120c is a covered offense. Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute it. When every guilty finding is for an offense after December 27, 2023, the military judge also sets the sentence within new sentencing parameters. Both rules depend on offense dates, which these records do not give, and the records cannot show whether either change affected the numbers here.

Cases resolved by nonjudicial punishment, administrative separation, or no action do not appear. 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](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 that charged Article 120c (61 cases). The trend line uses convictions whose records list the offenses found, by trial year.

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)
- [Army Courts-Martial: Data and Trends](https://www.bodiesburied.com/trends/army-courts-martial/) (hub)
- [By Offense](https://www.bodiesburied.com/trends/by-offense/) (hub)
- [Fewer or More? Indecent Recording And Exposure Charges at Air Force Courts-Martial, 2016–2025](https://www.bodiesburied.com/trends/air-force-article-120c-trend-2016-2025/) (another service)
- [Fewer or More? Indecent Recording And Exposure Charges at Navy-Marine Corps Courts-Martial, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-120c-trend-2017-2025/) (another service)
- [Army Article 107 Cases by the Numbers, 2021–2025](https://www.bodiesburied.com/trends/army-article-107-trend-2021-2025/)
- [Army Article 112a Cases by the Numbers, 2021–2025](https://www.bodiesburied.com/trends/army-article-112a-trend-2021-2025/)
- [Army Article 115 Cases by the Numbers, 2021–2025](https://www.bodiesburied.com/trends/army-article-115-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/)
- [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.