Indecent Recording And Exposure Plus Orders Violation: Courts-Martial Charging Articles 120c and 92
The records hold 24 Army, Navy, and Marine Corps courts-martial from 2014–2026 that charged both indecent recording and exposure under Article 120c and an orders violation under Article 92.
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Short answer: The records hold 24 Army, Navy, and Marine Corps courts-martial from 2014–2026 that charged both indecent recording and exposure under Article 120c and an orders violation under Article 92. 45% of these cases were contested, compared with 34% across all Article 120c cases in those services. Half of the confinement terms were 11 months or less, and the median for Article 120c cases overall was 1 year.
More Cases Were Contested
The plea is listed for 20 of the 24 cases. 9 accused contested at least one charge, meaning they pleaded not guilty to it, and 11 pleaded guilty. The contested share was 45%. Across all Army, Navy, and Marine Corps cases charging Article 120c, it was 34%.
What Else Was Charged
Article 92 appears in all 24 cases because that is how this group is defined. Article 120, sexual assault, was charged in 10 cases. Article 128, assault, was charged in 9. Article 134, the general article, appeared in 6, and Article 112a, drug offenses, in 3.
Because sentences cover every charge in a case, the sentences below reflect these other charges as well as Article 120c and Article 92.
Confinement After Conviction
22 cases ended in a conviction on at least one charge. Confinement was part of 82% of those sentences. Half of the confinement terms were 11 months or less, compared with a median of 1 year across all Army, Navy, and Marine Corps cases charging Article 120c.
A quarter of the terms in this group were 3.3 years or longer, and 1 sentence was life. These are adjudged sentences, meaning the sentence announced at trial. They come before any plea-agreement cap, clemency, or appeal.
Sentence Bands
4 convictions had no confinement (18%), compared with 9% across Article 120c cases. 6 had under 6 months (27%), compared with 23%. 4 had 6 months to 1 year (18%), compared with 28%.
Sentences of more than one year came less often here: 8 of 22 convictions (36%), compared with 40%. Of those, 5 were more than 1 year but under 5 years (23%), and 3 were 5 years or more (14%). Across Article 120c cases, those bands were 28% and 13%.
| Adjudged confinement | Convictions | Share here | Share, all Army, Navy, and Marine Corps cases charging Article 120c |
|---|---|---|---|
| No confinement | 4 | 18% | 9% |
| Under 6 months | 6 | 27% | 23% |
| 6 months to 1 year | 4 | 18% | 28% |
| More than 1 year, under 5 years | 5 | 23% | 28% |
| 5 years or more | 3 | 14% | 13% |
Court Level and Rank
17 of the 24 cases were general courts-martial (71%), close to the 69% across all Army, Navy, and Marine Corps cases charging Article 120c. A general court-martial can impose any lawful sentence. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge.
Junior enlisted members (E-1 to E-4) and NCOs each made up 46% of the accused, and officers made up 8%. Across all Article 120c cases in these services, junior enlisted members were 54% of the accused.
Bad-Conduct and Dishonorable Discharges
20 enlisted members were convicted, and 15 left with a punitive discharge: 12 bad-conduct discharges and 3 dishonorable discharges. Across Article 120c cases in these services, the punitive discharge share was 79%.
2 convicted officers or warrant officers appear, and 1 was dismissed. A sentence without a punitive discharge or dismissal does not rule out a later administrative separation.
Trial Years and Installations
The first trial was in September 2014 and the latest in April 2026. Counts by year were 1 in 2014, 3 in 2015, 1 in 2016, 2 in 2018, 2 in 2020, 8 in 2021, 3 in 2022, 2 in 2023, 1 in 2025, and 1 in 2026, a partial year. The records show no cases in 2017, 2019, or 2024.
Camp Pendleton, California, Camp Lejeune, North Carolina, and Mayport, Florida had 3 cases each. Fort Hood and Norfolk, Virginia had 2 each. These five installations account for 54% of the 24 cases. Larger installations try more cases of every kind, so a high count alone does not point to a problem at any one base.
Changes in the Law
The Military Justice Act of 2016 took effect on January 1, 2019, bringing fixed panel sizes, judge-alone special courts-martial, and written plea agreements. Article 120c is a covered offense. Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute covered offenses. When every guilty finding is for an offense after December 27, 2023, the military judge sets the sentence within new sentencing parameters.
What Is Missing From the Records
The records list trial dates but not offense dates, so they cannot show which rules applied to a given case. Only cases that reached a courtroom are counted. Nonjudicial punishment, administrative separation, and cases with no action are not included, and the evidence and plea terms are not described.
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.
How We Counted
Army, Navy, and Marine Corps courts-martial that charged both Article 120c and Article 92 (24 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 120c (Other Sexual Misconduct): Court-Martial Data and Trends (hub)
- Article 92 (Failure to Obey Order or Regulation): Court-Martial Data and Trends (hub)
- Articles 120c and 134 in the Same Case: What the Records Show
- Indecent Recording And Exposure Plus Assault: Courts-Martial Charging Articles 120c and 128
- When Article 120c and Article 80 Are Charged Together, How Do Cases End?
- Fewer or More? Indecent Recording And Exposure Charges at Army Courts-Martial, 2021–2025
- Fewer or More? Indecent Recording And Exposure Charges at Air Force Courts-Martial, 2016–2025
- Article 120c explained on the law firm's website
- Search every case in 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. This analysis is for education and information only. It is not legal advice, and every case is different.