Indecent Recording And Exposure Plus Assault: Courts-Martial Charging Articles 120c and 128

Trends › By Offense › Article 120c › With Article 128

Based on 51 cases · 2014–2026 · Army, Navy, and Marine Corps records · data updated October 24, 2026

Indecent Recording or Exposure With an Assault Charge

Article 120c covers indecent recording, broadcasting, and exposure. The 51 courts-martial here, tried between February 2014 and June 2026, also charged Article 128 (assault).

Every comparison below uses all Army, Navy, and Marine Corps cases charging Article 120c. This pairing differs most from that group in how often the accused contested the charges and how often the case was a general court-martial. The confinement figures are close to the comparison group.

More Contested Cases, Similar Verdicts

A case is contested when the accused pleads not guilty to at least one charge. The plea is listed in 40 of the 51 records: 22 were not-guilty or mixed pleas and 18 were guilty pleas. The contested share was 55%. For all Article 120c cases, it was 34%.

Verdicts in contested cases were similar to the comparison group. Of the 22 contested cases that reached a verdict, 32% ended in a full acquittal, about the same as the 31% for all Article 120c cases. Another 6 ended in a partial acquittal, meaning not guilty of at least one charge or specification and guilty of another.

Sentences by Court Level

General courts-martial, which can impose any lawful sentence, heard 41 of the 51 cases (80%), compared with 69% for all Article 120c cases. Special courts-martial heard the other 10. A special court-martial is capped at one year of confinement and cannot impose a dishonorable discharge.

The median confinement was 2 years at general courts-martial and 5 months at special courts-martial.

Confinement Was Similar to Other Article 120c Cases

Confinement was part of 86% of the 44 convictions. The median confinement was 1 year, the same as for all Article 120c cases. A quarter of the sentences were 2.8 years or longer.

Sentences longer than one year were given in 17 of 44 convictions (39%), compared with 40% in the comparison group. Each length was close to the comparison group. 10 convictions (23%) were under 6 months, the same share as the comparison group. 6 (14%) were 5 years or more, compared with 13%. Sentences with no confinement were more common: 14% compared with 9%.

All figures are adjudged sentences that cover every charge in the case, set before any plea-agreement cap, clemency, or appeal.

Discharges

Of 42 convicted enlisted members, 35 received a bad-conduct or dishonorable discharge (83%). That is higher than the 79% for all Article 120c cases. 18 of the 35 were dishonorable discharges.

Of 2 convicted officers or warrant officers, 1 was dismissed. Dismissal is the officer form of a punitive discharge. A sentence with no punitive discharge can still be followed by an administrative separation.

Sexual Assault Charges Were Also Common

Article 120 (sexual assault) was charged in 34 of the 51 cases, in addition to the indecent recording or exposure charge and the assault charge. Article 134 (general article) was charged in 14, Article 92 (orders violation) in 9, and Article 80 (attempt) in 6. Sentences cover all charges, so these other charges are part of the confinement and discharge figures.

Rank, Years, and Installations

Junior enlisted members (E-1 to E-4) were 59% of the accused, compared with 54% for all Article 120c cases. NCOs were 37% and officers were 4%.

No year had more than 9 cases, the count for 2021. 2017 and 2018 had 7 each, and 2025 had 1. The 2026 count of 3 covers part of the year.

Norfolk, Virginia, Camp Lejeune, North Carolina, and Bremerton, Washington had 4 cases each. Joint Base Lewis-McChord and Pearl Harbor, Hawaii had 3 each. These installations account for 35% of the 51 cases. Installations with more people try more cases of every kind, so these counts do not show a problem at any one base.

What the Records Do Not Show

The Military Justice Act of 2016, effective January 1, 2019, changed panel sizes and brought in written plea agreements. Whether it applied depended on the offense date. The records list only trial dates.

The records also do not include the evidence, the plea-agreement terms, or matters resolved through nonjudicial punishment or administrative separation. They do not explain why cases ended as they did.

For what the offense covers and how it is defended, see Article 120c on the law firm's website. Dates and sources for the law changes: UCMJ change timeline.

Compare: federal court. Aggravated Assault: Federal Sentences vs. Article 128 Courts-Martial, 2016–2025

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.