Property Damage Plus Larceny: Courts-Martial Charging Articles 109 and 121
In 2014–2026, 20 Army, Navy, and Marine Corps courts-martial charged both Article 109 (property damage) and Article 121 (larceny). The median confinement was 4 months, shorter than the 6 months in all Army, Navy, and Marine Corps cases charging Article 109.
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Short answer: In 2014–2026, 20 Army, Navy, and Marine Corps courts-martial charged both Article 109 (property damage) and Article 121 (larceny). The median confinement was 4 months, shorter than the 6 months in all Army, Navy, and Marine Corps cases charging Article 109. A punitive discharge followed 60% of enlisted convictions, compared with 57%.
Shorter Median Confinement
Every one of the 20 cases ended in a conviction, and 17 of those convictions carried confinement. The middle sentence was 4 months. For all Army, Navy, and Marine Corps cases charging Article 109, it was 6 months.
Among the sentences that included confinement, a quarter were 1 year or longer. The figures are adjudged sentences. They reflect the sentence announced at trial, before any plea-agreement cap, clemency, or appeal, and each one covers every charge in the case.
Sentence Bands
Under 6 months was the most common band, with 9 convictions (45%), compared with 40% for all Article 109 cases in these services. 4 convictions (20%) carried 6 months to 1 year, compared with 22%. 3 (15%) carried no confinement, compared with 13%.
Sentences longer than one year came less often than in all Army, Navy, and Marine Corps cases charging Article 109: 4 of 20 convictions (20%), against 25%. Of those, 3 (15%) fell between more than 1 year and under 5 years, compared with 18%, and 1 (5%) was 5 years or more, compared with 7%.
| Adjudged confinement | Convictions | Share here | Share, all Army, Navy, and Marine Corps cases charging Article 109 |
|---|---|---|---|
| No confinement | 3 | 15% | 13% |
| Under 6 months | 9 | 45% | 40% |
| 6 months to 1 year | 4 | 20% | 22% |
| More than 1 year, under 5 years | 3 | 15% | 18% |
| 5 years or more | 1 | 5% | 7% |
Fewer General Courts-Martial
There were 6 general and 14 special courts-martial. The general share, 30%, was lower than the 47% for all Army, Navy, and Marine Corps cases charging Article 109.
Only a general court-martial can adjudge more than one year of confinement or a dishonorable discharge. A special court-martial caps confinement at one year. It can impose a bad-conduct discharge but not a dishonorable discharge.
Bad-Conduct and Dishonorable Discharges
12 of 20 convicted enlisted members left with a punitive discharge. Of those, 10 were bad-conduct discharges and 2 were dishonorable discharges. In all Army, Navy, and Marine Corps cases charging Article 109, the share was 57%.
A sentence without a punitive discharge does not rule out a later administrative separation.
Charges Beyond Property Damage and Larceny
All 20 cases charged at least one other article besides Article 109. After Article 121, the most common were Article 134 (general article) in 6 cases and Article 130 (housebreaking before 2019; stalking since) in 6. Article 129 (burglary before 2019; burglary and unlawful entry since) appeared in 4, and Article 81 (conspiracy) in 4.
Guilty Pleas
The plea is listed in 15 of the 20 records. Of those, 10 accused pleaded guilty and 5 contested at least one charge. That is 33% contested, compared with 31% in all Army, Navy, and Marine Corps cases charging Article 109.
A contested case is one with a not-guilty or mixed plea. The records do not show the terms of any plea agreement.
Rank of the Accused
By rank, there were 14 junior enlisted members and 6 NCOs. No officers appear. The sheet describes this group as similar to all Army, Navy, and Marine Corps cases charging Article 109. Because no officers were charged, every conviction here is counted in the enlisted discharge figures.
Trial Years and Installations
The 20 cases were tried from October 2014 through April 2026. There were 2 in 2014, 4 in 2017, 1 in 2018, 4 in 2021, 1 in 2022, 2 in 2023, 3 in 2024, 1 in 2025, and 2 in 2026, a partial year. No cases were recorded in 2015, 2016, 2019, or 2020.
Camp Lejeune, North Carolina had 4 cases. MCAS Cherry Point, North Carolina, Fort Lee, and Camp Pendleton, California had 2 each, and San Diego, California had 1. These five installations account for 55% of the 20 cases. Larger installations try more cases of every kind, so a high count alone does not mean a base has a problem with these offenses.
Law Changes and Gaps in the Records
The Military Justice Act of 2016 took effect on January 1, 2019, and changed panel sizes, special courts-martial, and plea agreements. Since December 28, 2023, special trial counsel decide whether to prosecute covered offenses, and new sentencing parameters apply when every guilty finding is for an offense after December 27, 2023. The records give trial dates, not offense dates, so they cannot show which rules governed each case.
Nonjudicial punishment, administrative separation, and cases with no action are not in these records. The records also do not describe the evidence.
Dates and sources for the law changes mentioned here: UCMJ change timeline.
How We Counted
Army, Navy, and Marine Corps courts-martial that charged both Article 109 and Article 121 (20 cases). Air Force cases are left out because Air Force records rarely list the charges in acquittals.
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.
Related Analysis
- Article 109 (Property Other Than Military; Waste, Spoilage, Destruction): Court-Martial Data and Trends (hub)
- Article 121 (Larceny): Court-Martial Data and Trends (hub)
- Property Damage Plus Assault: Courts-Martial Charging Articles 109 and 128
- Articles 109 and 128b in the Same Case: What the Records Show
- Property Damage Plus Orders Violation: Courts-Martial Charging Articles 109 and 92
- How Has Article 109 Changed in Army Courts-Martial Since 2021?
- Air Force Article 109 Cases by the Numbers, 2016–2025
- Search every case in Military Trial Results (members)
Compare: federal court. Theft and Fraud by Dollar Loss: Federal Sentences vs. Article 121 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.