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How Army Larceny Cases Ended in 2022

The Army tried 38 courts-martial charging Article 121 (larceny) in 2022. The median confinement was 3 months, against 6 months for all Army cases, and 21% of cases were contested, against 36% Army-wide.

Understanding Trends in Military Practice · 5 min read

Trends › By Offense › Article 121 › Army, 2022

Short answer: The Army tried 38 courts-martial charging Article 121 (larceny) in 2022. The median confinement was 3 months, against 6 months for all Army cases, and 21% of cases were contested, against 36% Army-wide. 79% of convicted enlisted members received a punitive discharge, slightly higher than the 76% for the Army.

Based on 38 cases · 2022 · Army records · data updated October 24, 2026

Most Sentences Were Under 6 Months

35 cases ended in a conviction on at least one charge, and 31 of those sentences included confinement (89%). The median confinement was 3 months, compared with 6 months for all Army cases in 2022. A quarter of the sentences were 8 months or longer.

22 convictions (63%) were sentenced to under 6 months, compared with 41% Army-wide. 3 convictions (9%) were sentenced to 5 years or more, close to the 7% for the Army. In all, 6 of 35 convictions (17%) were sentenced to more than one year, compared with 27%.

Each figure is an adjudged sentence, set at trial before any plea-agreement cap, clemency, or appeal. Each sentence covers every charge in the case.

Adjudged confinementConvictionsShare hereShare, all Army cases in 2022
No confinement411%16%
Under 6 months2263%41%
6 months to 1 year39%16%
More than 1 year, under 5 years39%20%
5 years or more39%7%

More Punitive Discharges Than in 2021

79% of convicted enlisted members received a punitive discharge: 18 bad-conduct discharges and 5 dishonorable discharges. In 2021, the share for larceny cases was 64%. The Army-wide share in 2022 was 76%.

6 officers or warrant officers were convicted, and 2 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.

In this group, the median confinement was lower than for the Army, and the share of enlisted members with a punitive discharge was higher.

What Changed Since 2021?

The number of cases went from 41 in 2021 to 38 in 2022. The median confinement went from 5 months to 3 months. The share of convictions with any confinement went from 71% to 89%. General courts-martial went from 49% to 68% of cases.

The contested share moved from 15% to 21%, and full acquittals in decided contested cases went from 0 of 6 to 3 of 8. In groups this small, a few cases can change a percentage, so these changes show direction, not precise size.

20212022
Cases4138
Contested (of pleas recorded)15%21%
Full acquittals (decided contested)0 of 63 of 8
Convictions with confinement71%89%
Median confinement5 months3 months
Punitive discharge (enlisted)64%79%
General courts-martial49%68%

Pleas and Plea Agreements

Contested cases made up 21% of those with a plea recorded: 8 not-guilty or mixed pleas and 30 guilty pleas. A contested case is one where the accused pleads not guilty to at least one charge.

Of the 30 guilty pleas, 28 are recorded with a plea agreement and 2 have no entry. Army records say whether there was an agreement, not what it said.

General and Special Courts-Martial

A general court-martial can adjudge any lawful sentence, including long confinement and a dishonorable discharge. A special court-martial is capped at one year and cannot impose a dishonorable discharge. This group had 25 general and 12 special courts-martial, with the level not listed for 1 case.

At general courts-martial, the median confinement was 4 months, and 32% of cases were contested. At special courts-martial, the median confinement was 2 months, and 0% of cases were contested.

Only a general court-martial can adjudge more than one year of confinement. The 6 convictions with more than one year were therefore at general courts-martial.

Other Charges in the Same Cases

Article 121 was the only charge in 9 of 38 cases. Article 107 (false official statement) and Article 81 (conspiracy) were each charged in 9 cases. Article 112a (drug) was charged in 7, and Article 128b (domestic violence) and Article 134 (general article) in 5 each.

An adjudged sentence covers every finding. The sentences in this group include other convictions as well as the theft, and the records do not separate them.

Rank, Forum, and Location

By rank, 17 accused were junior enlisted, 15 were NCOs, and 6 were officers. That mix is more senior than all Army cases in 2022.

The accused usually chooses whether a military judge alone or a panel of members decides guilt. A military judge alone decided 34 of 38 cases (89%), and members heard 4, all enlisted panels. Most judge-alone cases are guilty pleas.

Fort Hood tried 9 of these cases, Joint Base Lewis-McChord 4, Fort Leonard Wood 3, and Kaiserslautern (Europe) and Fort Bragg 2 each. Together they account for 53% of the 38 cases. Larger installations try more cases of every kind.

What the Records Do Not Show

Trial records list charges, pleas, findings, and sentences. They do not show the evidence, the plea terms, the value of what was taken, or thefts handled outside a court-martial.

For what the offense covers and how it is defended, see Article 121 on the law firm's website. Dates and sources for the law changes: UCMJ change timeline.

How We Counted

Army courts-martial with a trial date in 2022 that charged Article 121 (38 cases), compared with all Army cases that year and with 2021.

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.

Compare: federal court. Theft and Fraud: Federal Sentences vs. Army Courts-Martial

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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