Article 121 Across the Services: Cases, Pleas, and Sentences, 2021–2025
Few contested larceny cases under Article 121 ended in a full acquittal from 2021–2025: 9 of 69 (13%), compared with 37% for all courts-martial in those years. The median confinement was 4 months, compared with 6 months overall.
Understanding Trends in Military Practice · 6 min read
Trends › By Offense › Article 121 › Across the services
Short answer: Few contested larceny cases under Article 121 ended in a full acquittal from 2021–2025: 9 of 69 (13%), compared with 37% for all courts-martial in those years. The median confinement was 4 months, compared with 6 months overall. The records hold 355 Article 121 cases in the Army, Air Force, Navy, and Marine Corps.
Full Acquittal Rates by Service
In the Navy-Marine Corps, 3% of the 35 contested Article 121 cases that reached a verdict ended in a full acquittal. In the Army, 20% of the 25 such cases did. Both rates are lower than the 37% for all courts-martial in those years.
Air Force records rarely list the charges in a case where the accused is acquitted of all charges. For that reason, no Air Force acquittal rate is given for a single offense such as larceny. The Air Force contested share and sentence figures are still shown.
| Service | Contested share | Cases with a plea recorded | Full acquittal (contested, verdict reached) | Contested cases with a verdict |
|---|---|---|---|---|
| Army | 15% | 162 | 20% | 25 |
| Air Force | 23% | 39 | — | — |
| Navy-Marine Corps | 25% | 146 | 3% | 35 |
Few Larceny Cases Were Contested
A contested case has a not-guilty or mixed plea to at least one charge. In the Army, only 15% of the 162 Article 121 cases with a plea recorded were contested. The Air Force share was 23% of 39, and the Navy-Marine Corps share was 25% of 146. The rest were guilty pleas.
The records do not say why an accused chose to plead guilty or to contest the charges.
Short Median Sentences
The Air Force had the shortest median confinement at 2 months, from 40 convictions. The Army median was 3 months from 157 convictions, and the Navy-Marine Corps median was 5 months from 146 convictions.
Confinement was part of 81% of Army sentences, 78% of Air Force sentences, and 75% of Navy-Marine Corps sentences. Sentences longer than 1 year were uncommon: 10% in the Army, 8% in the Air Force, and 10% in the Navy-Marine Corps.
These are adjudged sentences, before any plea-agreement cap, clemency, or appeal. When a larceny charge is tried with other charges, the sentence covers all of them. Across the three services, the median of 4 months was shorter than the 6-month median for all courts-martial in the same years.
| Service | Convictions | Included confinement | Median confinement | More than 1 year |
|---|---|---|---|---|
| Army | 157 | 81% | 3 months | 10% |
| Air Force | 40 | 78% | 2 months | 8% |
| Navy-Marine Corps | 146 | 75% | 5 months | 10% |
Discharges and Court Level
The Army imposed a punitive discharge on 67% of its 144 convicted enlisted members. The Air Force rate was 54% of 37, and the Navy-Marine Corps rate was 52% of 138. A punitive discharge is a bad-conduct or dishonorable discharge. A sentence without one does not rule out a later administrative separation.
The Army also tried 48% of its larceny cases at a general court-martial, compared with 32% in the Air Force and 24% in the Navy-Marine Corps. A special court-martial, where the rest were tried, caps confinement at one year and cannot impose a dishonorable discharge.
| Service | Convicted enlisted members | Punitive discharge | General court-martial share |
|---|---|---|---|
| Army | 144 | 67% | 48% |
| Air Force | 37 | 54% | 32% |
| Navy-Marine Corps | 138 | 52% | 24% |
Where the Cases Were Tried
The Army had 162 Article 121 cases and the Navy-Marine Corps had 149. The Air Force had 44. Larceny was charged in 8% of Navy-Marine Corps cases, 7% of Army cases, and 4% of Air Force cases in these years.
| Service | Cases charging Article 121 | Share of that service's cases |
|---|---|---|
| Army | 162 | 7% |
| Air Force | 44 | 4% |
| Navy-Marine Corps | 149 | 8% |
Trends From 2021 to 2025
The total count was 83 in 2021, 67 in 2022, 63 in 2023, 78 in 2024, and 64 in 2025. The Army count went from 41 in 2021 to 26 in 2025. The Navy-Marine Corps count stayed between 23 and 38.
The Air Force count rose over the period. It had 4 cases in 2021 and 6 in 2022, then 16 in 2024 and 11 in 2025.
| Year | Army | Air Force | Navy-Marine Corps |
|---|---|---|---|
| 2021 | 41 | 4 | 38 |
| 2022 | 38 | 6 | 23 |
| 2023 | 25 | 7 | 31 |
| 2024 | 32 | 16 | 30 |
| 2025 | 26 | 11 | 27 |
NCOs Were the Largest Group in the Army
In the Army, 51% of the accused with rank recorded were NCOs (E-5 to E-9), and 40% were junior enlisted (E-1 to E-4). The other services had more junior enlisted accused. In the Air Force, 57% were junior enlisted and 36% were NCOs. In the Navy-Marine Corps, 56% were junior enlisted and 41% were NCOs.
Officers made up 9% of Army accused, 7% of Air Force accused, and 3% of Navy-Marine Corps accused. The Navy-Marine Corps shares use 145 cases with rank listed.
| Service | Cases with rank | Junior enlisted (E-1 to E-4) | NCOs (E-5 to E-9) | Officers |
|---|---|---|---|---|
| Army | 162 | 40% | 51% | 9% |
| Air Force | 44 | 57% | 36% | 7% |
| Navy-Marine Corps | 145 | 56% | 41% | 3% |
Law Changes During These Years
Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute covered offenses such as sexual assault, domestic violence, and murder. For cases where all guilty findings are for offenses after December 27, 2023, the military judge sets the sentence within new sentencing parameters. The records give trial dates only, so trials from 2024 on mix cases under old and new rules.
Gaps in the Data
The records do not show the amount or type of property involved, the evidence, or the plea terms. They also leave out larceny handled by nonjudicial punishment, administrative separation, or no action at all. A case appears here when Article 121 was charged, whether or not the accused was convicted of it.
For what the offense covers and how it is defended, see Article 121 on the law firm's website. Dates and sources for the law changes: UCMJ change timeline.
How We Counted
Courts-martial in all three service groups with trial dates in 2021–2025 that charged Article 121 (355 cases). Coast Guard cases are not included.
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 121 (Larceny): Court-Martial Data and Trends (hub)
- By Offense (hub)
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- Army, Air Force, or Navy-Marine Corps: How Article 107 Cases Compare, 2021–2025
- Army, Air Force, or Navy-Marine Corps: How Article 117a Cases Compare, 2021–2025
- Army, Air Force, or Navy-Marine Corps: How Article 120 Cases Compare, 2021–2025
- Article 121 explained on the law firm's website
- 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.