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Army Cases Charging Both Article 121 and Article 134

In 25 Army courts-martial from 2021 to 2026, larceny under Article 121 was charged together with the general article, Article 134. The median confinement was 7 months, compared with 3 months across all Army Article 121 cases.

Understanding Trends in Military Practice · 5 min read

Trends › By Offense › Article 121 › Army, with Article 134

Short answer: In 25 Army courts-martial from 2021 to 2026, larceny under Article 121 was charged together with the general article, Article 134. The median confinement was 7 months, compared with 3 months across all Army Article 121 cases. Sentences longer than one year came in 24% of convictions, compared with 9%.

Based on 25 cases · 2021–2026 · Army records · data updated October 24, 2026

Longer Sentences Than Most Larceny Cases

All 25 cases ended in a conviction, and 18 of the 25 sentences included confinement. The median confinement was 7 months. In all Army Article 121 cases from 2021 to 2026, it was 3 months. A quarter of the confinement terms here were 2.3 years or longer.

6 of the 25 convictions (24%) carried more than one year. Across all Army Article 121 cases, the share was 9%. Terms of 5 years or more made up 12% here, compared with 4%, and so did terms of more than 1 year but under 5 years.

Each figure is an adjudged sentence, set at trial before any plea-agreement cap, clemency, or appeal. The sentence covers every charge in the case, not only the larceny.

Adjudged confinementConvictionsShare hereShare, Army-wide Article 121 cases
No confinement728%20%
Under 6 months624%57%
6 months to 1 year624%14%
More than 1 year, under 5 years312%4%
5 years or more312%4%

Fewer Short Terms

Terms under 6 months made up 24% of convictions, compared with 57% in all Army Article 121 cases. Terms of 6 months to 1 year made up 24%, compared with 14%.

Convictions with no confinement were more common here: 7 of 25 (28%), compared with 20%. So this group had more sentences at both ends of the range than the wider group.

General and Special Courts-Martial

General courts-martial heard 14 of the 25 cases (56%), compared with 46% in all Army Article 121 cases. Their median confinement was 1.5 years, and 43% of them were contested. The 11 special courts-martial had a median confinement of 3 months, and 18% were contested.

A general court-martial can impose any lawful sentence, including a dishonorable discharge. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge. Only a general court-martial can adjudge more than one year.

Pleas and Forum

17 accused pleaded guilty and 8 contested at least one charge, either with a not-guilty plea or a mixed plea. The contested share, 32%, is higher than the 15% across all Army Article 121 cases. 16 of the 17 guilty pleas are recorded with a plea agreement, and 1 has no entry. The records do not give the terms of any agreement.

A military judge alone decided guilt in 20 cases, and enlisted panels heard 5. No case went to an officer panel. Members heard 20% of these cases, compared with 8% in all Army Article 121 cases. Most judge-alone cases are guilty pleas, so the split mostly follows how many cases were contested.

Punitive Discharges for Enlisted Members

A punitive discharge followed 74% of enlisted convictions: 13 bad-conduct discharges and 4 dishonorable discharges. In all Army Article 121 cases, the share was 65%. A punitive discharge is a bad-conduct or dishonorable discharge for an enlisted member; for an officer, the equivalent is a dismissal.

2 convicted officers or warrant officers appear in the records, and 1 was dismissed. A sentence without a punitive discharge does not rule out an administrative separation later.

A More Senior Group

By rank, 8 accused were junior enlisted members (E-1 to E-4), 15 were NCOs (E-5 to E-9), and 2 were officers or warrant officers. In all Army Article 121 cases, 41% of the accused were junior enlisted, so this group is more senior.

Other charges in these cases included Article 107 (false official statement) in 7, Article 128b (domestic violence) in 6, Article 92 (orders violation) in 6, and Article 128 (assault) in 4. A case counts under each article it included.

Years and Installations

The cases were tried from February 2021 through June 2026: 8 in 2021, 5 in 2022, 5 in 2023, 2 in 2024, 4 in 2025, and 1 in 2026, a partial year.

Joint Base Elmendorf-Richardson had the most cases, 4. Wheeler Army Airfield had 3, and Fort Carson, Joint Base Lewis-McChord, and Fort Drum had 2 each. These five account for 52% of the cases. Larger installations try more cases of every kind.

What the Records Leave Out

The records give trial dates, not offense dates. Since December 28, 2023, the military judge sets the sentence under new sentencing parameters when every guilty finding is for an offense after December 27, 2023, and special trial counsel decide whether covered offenses go to trial. Without offense dates, trials from 2024 on mix old-rule and new-rule cases.

The records do not describe the evidence or the plea terms. Cases handled by nonjudicial punishment or administrative separation are not included, and Army records in this data are sparse before 2021.

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 trial dates in 2021–2026 that charged both Article 121 and Article 134 (25 cases), compared with all 187 Army Article 121 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.

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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