Fewer or More? Stalking Charges at Army Courts-Martial, 2021–2025

Trends › By Offense › Article 130 › Army

Based on 16 cases · 2021–2025 · Army records · data updated October 24, 2026

Punitive Discharges in Almost Every Enlisted Conviction

11 of the 12 convicted enlisted members received a punitive discharge: 8 bad-conduct discharges and 3 dishonorable discharges. The Army-wide share was 73%.

1 convicted officer or warrant officer appears in these cases, and that officer was dismissed. A dismissal is the officer equivalent of a punitive discharge. A sentence without either does not rule out an administrative separation later.

Nearly All General Courts-Martial

15 of the 16 cases were general courts-martial, the level that can impose long confinement and a dishonorable discharge. The other case was a special court-martial.

Confinement in 8 of 13 Sentences

13 of the 16 cases ended in a conviction on at least one charge. 8 of those 13 sentences included confinement (62%). The median confinement was 10 months, longer than the 6 months for the Army as a whole. A quarter of the terms were 3.5 years or longer.

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

Stalking Was Usually Charged With Other Offenses

15 of the 16 cases charged at least one other article. Article 128 (assault) and Article 128b (domestic violence) each appeared in 7 cases. Article 134 (general article) appeared in 5, and Article 120 (sexual assault) and Article 115 (communicating threats) each in 4.

Pleas and Plea Agreements

10 accused pleaded guilty and 6 contested. The contested share, 38%, is higher than the 30% Army-wide. A contested case is one with a not-guilty or mixed plea.

9 of the 10 guilty pleas are recorded with a plea agreement, and 1 has no entry. Army records say whether there was an agreement, not what it said.

Forum and Rank

A military judge alone decided 13 cases. Members heard 3 (19%), all with enlisted panels.

The accused were 8 junior enlisted members (E-1 to E-4), 6 NCOs (E-5 to E-9), and 2 officers or warrant officers. This group is more senior than the Army as a whole, where 55% of the accused were junior enlisted.

A Peak in 2023

The yearly count was 2 in 2021, 1 in 2022, 8 in 2023, 3 in 2024, and 2 in 2025. Convictions including Article 130 also peaked in 2023, at 4.

Article 130 was part of 1 of 891 Army convictions in 2021–2022 (0%) and 3 of 816 in 2024–2025 (0%), about the same share.

Rules and Gaps

Article 130 is a covered offense. Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute it. The records give trial dates, not offense dates, so trials from 2024 on include cases under both old and new rules. They do not describe the evidence, and they leave out cases resolved by nonjudicial punishment, administrative separation, or no action.

Dates and sources for the law changes mentioned here: UCMJ change timeline.

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.