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# When Article 120c and Article 80 Are Charged Together, How Do Cases End?
- URL: https://www.bodiesburied.com/trends/article-120c-and-article-80-charged-together/
- Published: 2026-10-28T06:55:34.000Z
- Updated: 2026-10-30T08:14:51.000Z
- Description: In cases that charged Article 120c with an attempt charge, 93% of convicted enlisted members received a punitive discharge, compared with 79% for all Article 120c cases.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 120c, Article 80

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 120c](https://www.bodiesburied.com/trends/article-120c-courts-martial/) › With Article 80

**Short answer:** In cases that charged Article 120c with an attempt charge, 93% of convicted enlisted members received a punitive discharge, compared with 79% for all Article 120c cases. In these 49 Army, Navy, and Marine Corps courts-martial from 2014–2026, only 2 of 15 contested cases that reached a verdict ended in a full acquittal (13%), compared with 31% in the broader group.

Based on 49 cases · 2014–2026 · Army, Navy, and Marine Corps records · data updated October 24, 2026

## Most Enlisted Convictions Included a Punitive Discharge

Article 120c covers indecent recording, broadcasting, and exposure. Article 80 covers attempting an offense. The 49 cases here charged both, with trials from December 2014 through May 2026.

A punitive discharge is a bad-conduct or dishonorable discharge for an enlisted member. A punitive discharge was part of the sentence in 93% of enlisted convictions: 23 bad-conduct and 17 dishonorable. For all Army, Navy, and Marine Corps cases charging Article 120c, the share was 79%.

Of 4 convicted officers or warrant officers, 3 were dismissed. Dismissal is the officer form of a punitive discharge. An administrative separation can still follow a sentence without a punitive discharge.

## Few Full Acquittals

A case is contested when the accused pleads not guilty to at least one charge. Of the 15 contested cases that reached a verdict, 2 ended in a full acquittal. The rate was 13%, compared with 31% for all Article 120c cases. Another 6 ended in a partial acquittal, with an acquittal on at least one charge or specification and a conviction on another.

There were few contested cases, so a few different verdicts would change these figures.

## The Contested Share Was Slightly Higher

The plea is listed in 39 of the 49 records: 24 guilty pleas and 15 contested cases. The contested share was 38%, slightly higher than the 34% for all Article 120c cases.

The low full-acquittal rate is not explained by a small contested share. The contested share here was slightly higher than in the comparison group.

## Almost Every Conviction Included Confinement

Of 47 convictions, 46 included confinement. The median confinement was 1 year, the same as the 1 year median for all Article 120c cases. A quarter of the sentences were 3 years or longer, and 1 was a life sentence.

Confinement of more than one year was given in 22 of 47 convictions (47%), compared with 40% in the comparison group. Most lengths of confinement were close to the comparison group. The exception is no confinement: 1 conviction (2%), compared with 9% for all Article 120c cases.

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

| Adjudged confinement            | Convictions | Share here | Share, all Army, Navy, and Marine Corps cases charging Article 120c |
| ------------------------------- | ----------- | ---------- | ------------------------------------------------------------------- |
| No confinement                  | 1           | 2%         | 9%                                                                  |
| Under 6 months                  | 10          | 21%        | 23%                                                                 |
| 6 months to 1 year              | 14          | 30%        | 28%                                                                 |
| More than 1 year, under 5 years | 15          | 32%        | 28%                                                                 |
| 5 years or more                 | 7           | 15%        | 13%                                                                 |

## General and Special Courts-Martial

General courts-martial made up 76% of these cases (37 of 49). This is the level that can impose long confinement and a dishonorable discharge. The other 12 were special courts-martial, where confinement is capped at one year and a dishonorable discharge is not available.

The median confinement was 1.9 years at general courts-martial and 6 months at special courts-martial.

## More NCOs Than Junior Enlisted Members

NCOs (E-5 to E-9) were the largest group of accused, with 26\. There were 19 junior enlisted members (E-1 to E-4) and 4 officers or warrant officers. Junior enlisted members were 54% of the accused in all Article 120c cases, so this group was more senior.

## Other Charges in These Cases

Article 134 (general article) was charged in 20 of the 49 cases. Article 120b (child sexual abuse) and Article 128 (assault) were each charged in 6, and Article 120 (sexual assault) in 5\. Sentences cover all charges in a case, not only the 2 charges in the title.

## Years and Installations

The highest yearly count was 10 cases in 2021\. There were 7 in 2017 and 5 each in 2018 and 2020\. Recent years had fewer cases, and the 2026 count of 3 covers part of the year.

Norfolk, Virginia and Camp Lejeune, North Carolina had 7 cases each. San Diego, California, Fort Hood, and Fort Knox had 3 each. These installations account for 47% of the 49 cases. Large installations try more cases of every kind, so the list shows where trials took place, not a problem at any one base.

## What the Records Do Not Show

Rule changes such as the Military Justice Act of 2016, effective January 1, 2019, apply by offense date. The records list only trial dates, so they cannot sort cases by which rules applied. The records also do not show the evidence, the plea terms, or matters handled by nonjudicial punishment or administrative separation. They cannot show why a case ended as it did.

For what the offense covers and how it is defended, see [Article 120c on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-120c/?ref=bodiesburied.com). Dates and sources for the law changes: [UCMJ change timeline](https://www.bodiesburied.com/trends/ucmj-change-timeline/).

### How We Counted

Army, Navy, and Marine Corps courts-martial that charged both Article 120c and Article 80 (49 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](https://www.bodiesburied.com/military-trial-results/), data updated October 24, 2026\. Definitions, sources, and known gaps: [how this data was built](https://www.bodiesburied.com/trends/how-the-military-trial-results-data-was-built/). Errors: content@bodiesburied.com.

## Related Analysis

- [Article 120c (Other Sexual Misconduct): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-120c-courts-martial/) (hub)
- [Article 80 (Attempts): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-80-courts-martial/) (hub)
- [Articles 120c and 134 in the Same Case: What the Records Show](https://www.bodiesburied.com/trends/article-120c-and-article-134-charged-together/)
- [Indecent Recording And Exposure Plus Assault: Courts-Martial Charging Articles 120c and 128](https://www.bodiesburied.com/trends/article-120c-and-article-128-charged-together/)
- [Indecent Recording And Exposure Plus Orders Violation: Courts-Martial Charging Articles 120c and 92](https://www.bodiesburied.com/trends/article-120c-and-article-92-charged-together/)
- [Fewer or More? Indecent Recording And Exposure Charges at Army Courts-Martial, 2021–2025](https://www.bodiesburied.com/trends/army-article-120c-trend-2021-2025/)
- [Fewer or More? Indecent Recording And Exposure Charges at Air Force Courts-Martial, 2016–2025](https://www.bodiesburied.com/trends/air-force-article-120c-trend-2016-2025/)
- [Article 120c explained on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-120c/?ref=bodiesburied.com)
- [Search every case in Military Trial Results](https://www.bodiesburied.com/military-trial-results/) (members)

**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](https://www.ucmj-defender.com/?ref=bodiesburied.com). This analysis is for education and information only. It is not legal advice, and every case is different.