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# Articles 121 and 134 in the Same Case: What the Records Show
- URL: https://www.bodiesburied.com/trends/article-121-and-article-134-charged-together/
- Published: 2026-10-28T06:55:31.000Z
- Updated: 2026-11-03T01:47:16.000Z
- Description: In larceny cases that also included an Article 134 charge, the median confinement was 11 months, compared with 5 months for all Article 121 cases.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 121, Article 134

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 121](https://www.bodiesburied.com/trends/article-121-courts-martial/) › With Article 134

**Short answer:** In larceny cases that also included an Article 134 charge, the median confinement was 11 months, compared with 5 months for all Article 121 cases. In these 54 Army, Navy, and Marine Corps courts-martial from 2013–2026, 79% of convicted enlisted members received a punitive discharge, compared with 64% in the broader group.

Based on 54 cases · 2013–2026 · Army, Navy, and Marine Corps records · data updated October 24, 2026

## Longer Sentences for Larceny Plus the General Article

Article 134, the general article, covers conduct prejudicial to good order and discipline or discrediting to the service, along with a set of specific listed offenses. It was charged with Article 121 (larceny) in 54 courts-martial tried from November 2013 through June 2026.

Every case ended in a conviction, and 44 of the 54 sentences included confinement. The median confinement was 11 months, compared with the 5 months median for all Army, Navy, and Marine Corps cases charging Article 121\. A quarter of the sentences were 2 years or longer.

## Sentences by Length

Confinement of more than one year was given in 17 of 54 convictions, or 31%, compared with 12% for all Article 121 cases. 13 convictions (24%) were more than 1 year but under 5 years, compared with 10%. 4 convictions (7%) were 5 years or more.

Short sentences were less common. Sentences under 6 months made up 19% of convictions here and 43% in the comparison group. The share with no confinement was 19%, about the same as the 17% for all Article 121 cases. These are adjudged sentences for every charge in the case, set before any plea-agreement cap, clemency, or appeal.

| Adjudged confinement            | Convictions | Share here | Share, all Army, Navy, and Marine Corps cases charging Article 121 |
| ------------------------------- | ----------- | ---------- | ------------------------------------------------------------------ |
| No confinement                  | 10          | 19%        | 17%                                                                |
| Under 6 months                  | 10          | 19%        | 43%                                                                |
| 6 months to 1 year              | 17          | 31%        | 28%                                                                |
| More than 1 year, under 5 years | 13          | 24%        | 10%                                                                |
| 5 years or more                 | 4           | 7%         | 2%                                                                 |

## About Equal Numbers at Each Court Level

General courts-martial heard 28 of the cases and special courts-martial heard 26\. The general court-martial share was 52%, compared with 31% for all Article 121 cases. Only a general court-martial can adjudge more than one year of confinement or a dishonorable discharge.

At general courts-martial, the median confinement was 1.9 years and 33% of cases were contested. At special courts-martial, the median was 6 months and 23% were contested.

## Discharges and Dismissals

A punitive discharge was part of the sentence in 79% of enlisted convictions, compared with 64% for all Article 121 cases. There were 32 bad-conduct discharges and 9 dishonorable discharges.

Of 2 convicted officers or warrant officers, 1 was dismissed. Dismissal is the officer form of a punitive discharge. A sentence without a punitive discharge can still be followed by an administrative separation.

## More Contested Cases

A contested case is one in which the accused pleaded not guilty to at least one charge. The plea is listed in 50 of 54 records: 36 guilty pleas and 14 contested cases. The contested share was 28%, compared with 15% for all Article 121 cases.

Every case in this group ended in a conviction on at least one charge. A contested case can end in a partial acquittal, meaning not guilty of at least one charge or specification and guilty of another, and still lead to a sentence. With 14 contested cases, the records do not support a separate acquittal rate for this pairing.

## Other Charges in These Cases

In the comparison group, 190 of 675 Article 121 cases charged larceny alone. In this group, Article 92 (orders violation) was also charged in 17 cases, Article 107 (false official statement) in 13, Article 128 (assault) in 9, and Article 128b (domestic violence, numbered since 2019) in 7.

## Rank of the Accused

NCOs made up 50% of the accused, junior enlisted members (E-1 to E-4) 46%, and officers 4%. For all Article 121 cases, junior enlisted members were 51%. This group was slightly more senior.

## Most Cases Were Tried in Recent Years

Before 2019, these cases were uncommon. No year had more than 2, and 2014 and 2017 had 0\. There were 16 cases in 2021, and each full year since then has had between 5 and 8\. The 2026 count of 3 covers part of the year.

Camp Lejeune, North Carolina had the most cases, with 6\. Marine Corps Base Hawaii, Kaneohe Bay and Joint Base Elmendorf-Richardson had 4 each, and Wheeler Army Airfield and Bremerton, Washington had 3 each. These installations account for 37% of the 54 cases. Larger installations try more cases overall, so the counts do not by themselves say anything about one base.

## What the Records Do Not Show

The Military Justice Act of 2016 took effect on January 1, 2019\. New sentencing parameters apply when every guilty finding is for an offense after December 27, 2023\. Both depend on offense dates, which these trial records do not give.

The records also do not include the evidence, the plea-agreement terms, nonjudicial punishment, or administrative separations. They do not show why a case ended the way it did.

For what the offense covers and how it is defended, see [Article 121 on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-121/?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 121 and Article 134 (54 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 121 (Larceny): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-121-courts-martial/) (hub)
- [Article 134 (General Article): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-134-courts-martial/) (hub)
- [Articles 121 and 92 in the Same Case: What the Records Show](https://www.bodiesburied.com/trends/article-121-and-article-92-charged-together/)
- [Larceny Plus Conspiracy: Courts-Martial Charging Articles 121 and 81](https://www.bodiesburied.com/trends/article-121-and-article-81-charged-together/)
- [Articles 121 and 80 in the Same Case: What the Records Show](https://www.bodiesburied.com/trends/article-121-and-article-80-charged-together/)
- [Army Article 121 Cases by the Numbers, 2021–2025](https://www.bodiesburied.com/trends/army-article-121-trend-2021-2025/)
- [Air Force Article 121 Cases by the Numbers, 2016–2025](https://www.bodiesburied.com/trends/air-force-article-121-trend-2016-2025/)
- [Article 121 explained on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-121/?ref=bodiesburied.com)
- [Search every case in Military Trial Results](https://www.bodiesburied.com/military-trial-results/) (members)

**Compare: federal court.** [Theft and Fraud by Dollar Loss: Federal Sentences vs. Article 121 Courts-Martial](https://www.bodiesburied.com/trends/federal-theft-fraud-dollar-loss-vs-article-121/)

**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.