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Larceny at Army Courts-Martial, 2023: The Year in Numbers

In 2023 the Army tried 25 courts-martial charging Article 121 (larceny), and more of the accused were NCOs than junior enlisted members. 16% of cases were contested, compared with 31% Army-wide.

Understanding Trends in Military Practice · 6 min read

Trends › By Offense › Article 121 › Army, 2023

Short answer: In 2023 the Army tried 25 courts-martial charging Article 121 (larceny), and more of the accused were NCOs than junior enlisted members. 16% of cases were contested, compared with 31% Army-wide. The median confinement was 3 months, compared with 6 months, and 65% of convicted enlisted members received a punitive discharge, compared with 74%.

Based on 25 cases · 2023 · Army records · data updated October 24, 2026

Rank of the Accused

By rank, 17 accused were NCOs, 7 were junior enlisted, and 1 was an officer. That mix is more senior than all Army cases in 2023.

The records list rank at the time of trial. They do not describe duty positions, access to funds or property, or the amounts involved. They cannot show what kinds of theft these cases involved.

Guilty Pleas and Plea Agreements

21 accused pleaded guilty and 4 contested at least one charge. A contested case is one with a not-guilty plea to at least one charge. The contested share was 16%, lower than the 31% for all Army cases in 2023.

All 21 guilty pleas are recorded with a plea agreement. Army records show that an agreement existed, not its terms. Any cap on confinement does not appear in the figures below. 1 of the 4 contested cases that reached a verdict ended in a full acquittal. That count is too small to treat as a rate.

Most Sentences Were Under 6 Months

20 of 24 convictions included confinement. The median confinement was 3 months, compared with 6 months across the Army. A quarter of the sentences were 7 months or longer.

14 convictions (58%) were sentenced to under 6 months, compared with 39% for all Army cases. 4 convictions (17%) had no confinement, about the same as the 16% for the Army. Sentences of more than one year were less common: 3 of 24 convictions (12%), compared with 28% Army-wide. 2 of those were 5 years or more.

These are adjudged sentences, set at trial before any plea-agreement cap, clemency, or appeal. Each covers every charge in the case.

Adjudged confinementConvictionsShare hereShare, all Army cases in 2023
No confinement417%16%
Under 6 months1458%39%
6 months to 1 year312%16%
More than 1 year, under 5 years14%21%
5 years or more28%8%

Fewer Punitive Discharges Than in 2022

15 of 23 convicted enlisted members received a bad-conduct or dishonorable discharge (65%), lower than the 74% for all Army cases in 2023. 2 of those were dishonorable discharges.

1 officer or warrant officer was convicted and was dismissed. Dismissal is the officer equivalent of a punitive discharge. A sentence without a punitive discharge can still be followed by an administrative separation, which these records do not show.

Most of the accused in this group were NCOs, so the 65% figure mostly describes NCOs. The records do not show length of service or the effect of any discharge on benefits.

What Changed Since 2022?

The number of cases went from 38 in 2022 to 25 in 2023. The general court-martial share went from 68% to 36%. Punitive discharges for convicted enlisted members went from 79% to 65%. The contested share went from 21% to 16%.

The median confinement was 3 months in both years. Convictions with confinement went from 89% to 83%. Full acquittals in decided contested cases went from 3 of 8 to 1 of 4. In groups this small, a few cases can change a percentage, so these changes show direction, not precision.

20222023
Cases3825
Contested (of pleas recorded)21%16%
Full acquittals (decided contested)3 of 81 of 4
Convictions with confinement89%83%
Median confinement3 months3 months
Punitive discharge (enlisted)79%65%
General courts-martial68%36%

Court Level

General courts-martial, the level that can impose long confinement and a dishonorable discharge, made up 36% of the 22 cases with a court level listed (8 of 22). The rest were special courts-martial. A special court-martial is capped at one year of confinement and cannot adjudge a dishonorable discharge.

Only a general court-martial can adjudge more than one year. The 3 convictions with more than one year were therefore among the 8 general courts-martial.

Other Charges in the Same Cases

19 of the 25 cases charged at least one other article. Article 107 (false official statement) was charged in 6, Article 134 (general article) in 5, and Article 105 (forgery), Article 92 (orders violation), and Article 81 (conspiracy) in 2 each.

Each sentence covers all findings in a case. For a case with both larceny and false statement convictions, the records do not show how much of the sentence was for either charge.

Forum and Installations

The accused usually chooses whether a military judge alone or a panel of members decides guilt. A military judge alone decided 24 cases, and an enlisted panel heard 1. Members heard 4% of the cases, compared with 19% for all Army cases in 2023.

Joint Base Lewis-McChord tried 5 of these cases, Wheeler Army Airfield 3, and Fort Campbell, Fort McNair, and Camp Humphreys 2 each. Together they account for 56% of the 25 cases. Larger installations try more cases of every kind.

What the Records Do Not Show

The records give trial dates, not offense dates. They do not describe the evidence or the plea terms. Thefts handled by nonjudicial punishment or administrative separation do not appear.

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 2023 that charged Article 121 (25 cases), compared with all Army cases that year and with 2022.

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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