Guilty Pleas in Child Pornography Cases: Federal Court vs. Courts-Martial
Among 423 courts-martial charging child pornography (images of child exploitation) with a plea recorded, 337 were guilty pleas, which is 80%. In federal court, 13,224 of 13,646 people sentenced, or 97%, pleaded guilty. The guilty plea share in courts-martial has changed over the years in the records
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In brief: Among 423 courts-martial charging child pornography (images of child exploitation) with a plea recorded, 337 were guilty pleas, which is 80%. In federal court, 13,224 of 13,646 people sentenced, or 97%, pleaded guilty. The guilty plea share in courts-martial has changed over the years in the records, and the federal share has not.
This post uses the U.S. Sentencing Commission's records of 13,646 people sentenced in federal court in fiscal years 2016 to 2025 and the Federal Judicial Center's records of 14,551 federal defendants whose cases ended in fiscal years 2016 to 2025, compared with court-martial results from this site's Military Trial Results data (updated November 2, 2026). It is part of the Federal Prosecution Analysis series, which builds on Military Moves Toward Sentencing Guidelines to Mirror the Federal System. How the numbers were built: How the Federal Comparison Data Was Built.
How Often Did Courts-Martial End in a Guilty Plea?
Court-martial records show a plea for 423 courts-martial charging child pornography: possession, receipt, or distribution, with trial dates from 2016 to 2025. Of those, 337 were guilty pleas (80%), 22 were mixed pleas (5%), and 64 were not-guilty pleas (15%). A mixed plea means not guilty to at least one charge.
Another 69 courts-martial charging this offense have no plea recorded, so they are not part of these percentages.
How Does the Rate Differ by Service?
The Army has the highest share of guilty pleas: 123 of 133 recorded pleas, or 92%. The Marine Corps follows with 77 of 99, or 78%. The Air Force and the Navy each have 72%, with 83 of 116 and 54 of 75.
Air Force plea information is missing for most trials before 2020. That makes the Air Force figure less complete than the others.
| Service | Cases with a plea recorded | Guilty pleas | Share |
|---|---|---|---|
| Army | 133 | 123 | 92% |
| Air Force | 116 | 83 | 72% |
| Navy | 75 | 54 | 72% |
| Marine Corps | 99 | 77 | 78% |
Has the Share Changed Since 2020?
The year-by-year table shows guilty pleas in 2020 at 13 of 17 cases, or 76%. The share was 74% in 2021 and 76% in 2022. It was 84% in 2023, 85% in 2024, and 88% in 2025.
Counts from 2016 to 2019 are 8 cases or fewer in each year, so percentages for those years are not meaningful. The records do not show why the share rose in the later years.
| Year | Courts-martial: guilty pleas | Federal: pleaded guilty |
|---|---|---|
| 2016 | 5 of 8 (5 of 8) | 97% |
| 2017 | 4 of 7 (4 of 7) | 96% |
| 2018 | 1 of 6 (1 of 6) | 96% |
| 2019 | 3 of 4 (3 of 4) | 97% |
| 2020 | 13 of 17 (76%) | 97% |
| 2021 | 52 of 70 (74%) | 98% |
| 2022 | 58 of 76 (76%) | 97% |
| 2023 | 58 of 69 (84%) | 97% |
| 2024 | 73 of 86 (85%) | 97% |
| 2025 | 70 of 80 (88%) | 97% |
What Is a Plea Agreement in These Cases?
Records show whether there was a plea agreement for 247 of the court-martial guilty pleas. Of those, 240 had one, which is 97%. These records come mostly from the Army, Navy, and Marine Corps.
In federal court, 86% of guilty pleas had a written plea agreement, and 14% were straight pleas with no agreement.
What Does Federal Court Show?
The U.S. Sentencing Commission counts people sentenced. Of 13,646 sentenced in fiscal years 2016 to 2025, 422 were convicted at trial. Everyone else pleaded guilty.
The Federal Judicial Center counts defendants whose cases ended. Of 14,551 defendants charged under 18 U.S.C. 2252 or 2252A, 13,743 pleaded guilty (94%), 480 had their cases dismissed (3%), and 328 went to trial (2%). A total of 14,062 were convicted, by plea or at trial, which is 97%.
What Does the Comparison Not Show?
The court-martial percentages use only cases with a recorded plea. The federal sentencing percentages count only people who were sentenced, so they leave out dismissals. The Federal Judicial Center figures include dismissals, which lowers the guilty plea share to 94%.
The records cannot explain why the guilty plea share differs between the systems. A federal felony needs a grand jury indictment, while a court-martial has no grand jury.
How We Counted
Courts-martial: every court-martial charging child pornography (images of child exploitation): possession, receipt, or distribution with a trial date in 2016 to 2025 and a plea recorded (423). Federal: people sentenced under primary sentencing guideline §2G2.2 (possessing, receiving, or distributing child pornography; 18 U.S.C. 2252 and 2252A) (13,646, U.S. Sentencing Commission) and defendants charged under 18 U.S.C. 2252 or 2252A whose cases ended (14,551, Federal Judicial Center), fiscal years 2016 to 2025.
Federal fiscal years run from October 1 to September 30. No person, judge, or lawyer is identified in any of these records.
What to Keep in Mind
Who is in each set of numbers. The federal sentencing numbers come from the U.S. Sentencing Commission. They count only people who were convicted and sentenced in federal district court. People whose cases were dismissed or who were acquitted are not in them. The military numbers come from court-martial results, which include acquittals. To compare acquittal or dismissal rates, the federal side uses a different source: the Federal Judicial Center's case data, which counts every defendant whose case ended.
Different cases reach each system. Federal prosecutors bring a narrow set of cases. In fiscal year 2024, immigration and drug trafficking cases were 59% of everyone sentenced in federal court (36,664 of 61,678). Many crimes that the military prosecutes, such as most assaults, most sexual assaults between adults, and drug use, are usually state crimes for civilians and reach federal court only in special situations, such as on federal land or in Indian Country. A federal case and a court-martial for the same crime can involve different kinds of facts.
Time periods. Federal numbers are by federal fiscal year (October 1 to September 30), based on the sentencing date. The military numbers are by trial date. Neither source has the date of the offense, so a change in law shows up in either data set gradually.
Offense categories do not line up exactly. Each comparison uses a federal offense group chosen to match the military article as closely as possible (see the crosswalk). Some matches are close; others are partial. The post says which federal guideline or statute was used and why it is not an exact match.
Mandatory minimum sentences. Many federal statutes on drugs, images of child exploitation, child sex abuse, and firearms carry mandatory minimum prison terms. The UCMJ has mandatory minimums only for a few offenses (a dishonorable discharge or dismissal for rape and sexual assault, and life for premeditated murder). Federal sentences for these offenses are partly set by Congress, not by the judge.
Plea agreements work differently. In federal court, most plea agreements do not bind the judge on the sentence. Since 2019, a military plea agreement can set a minimum and maximum sentence that the military judge must follow if the judge accepts the agreement. The federal numbers count anyone who pleaded guilty, with or without a written agreement.
How "plea" and "trial" are counted. In the federal sentencing numbers, "trial" means the person was convicted after a trial, including people who pleaded guilty to some counts and went to trial on others. People acquitted at trial are not in these numbers at all (see "Who is in each set of numbers"). In the federal case data, the trial rate counts both convictions and acquittals at trial among all defendants whose cases ended, including dismissed cases. Military numbers count contested cases that reached a verdict. These denominators are not the same, and each post states the one it uses.
Related Analysis
- Military Moves Toward Sentencing Guidelines to Mirror the Federal System (the background article)
- Federal Prosecution Analysis (all federal posts)
- How the Federal Comparison Data Was Built (sources and method)
- Child Pornography Sentences: Federal Court vs. Courts-Martial, 2016–2025 (overview)
- Child Pornography Sentences Since the 2023 Military Sentencing Reform: What the Data Shows So Far
- Child Pornography Charges: Federal Trial Acquittals vs. Contested Army Courts-Martial
- Child Pornography Charges: How Often Federal Trials and Courts-Martial End in Acquittal
- Child Pornography Charges: Federal Trial Acquittals vs. Contested Marine Corps Courts-Martial
- Child Pornography Charges: Federal Trial Acquittals vs. Contested Navy Courts-Martial
- Child Pornography Convictions of Junior Enlisted (E-1 to E-4): Courts-Martial Compared With Federal Court
- Are Courts-Martial More Likely to End in Acquittal Than Federal Trials? (related comparison)
- Guilty Pleas in Federal Court vs. Courts-Martial, Year by Year (related comparison)
- Federal Law Has No Crime of Drug Use: How Article 112a Cases Compare (related comparison)
- Drug Distribution and Importation: Federal vs. Court-Martial Sentences, 2016–2025 (related comparison)
- Sexual Abuse of an Adult: Federal Cases vs. Article 120 Courts-Martial (related comparison)
- Child Sexual Abuse and Enticement: Federal Cases vs. Article 120b Courts-Martial (related comparison)
- Theft and Fraud by Dollar Loss: Federal Sentences vs. Article 121 Courts-Martial (related comparison)
- Fewer or More? General Article Charges at Army Courts-Martial, 2021–2025 (court-martial data)
- What Sentence Follows an Army General Article Conviction? (court-martial data)
- Fighting an Army General Article Charge: How Contested Cases Ended (court-martial data)
- Guilty Pleas in Army General Article Cases: How Often, and What Came Next (court-martial data)
- Air Force Article 134 Cases by the Numbers, 2016–2025 (court-martial data)
- What Sentence Follows an Air Force General Article Conviction? (court-martial data)
- Guilty Pleas in Air Force General Article Cases: How Often, and What Came Next (court-martial data)
- Is Navy-Marine Corps General Article Prosecution Rising or Falling? Article 134, 2017–2025 (court-martial data)
- What Sentence Follows a Navy-Marine Corps General Article Conviction? (court-martial data)
- Not Guilty Pleas in Navy-Marine Corps Article 134 Cases: What Happened at Trial (court-martial data)
- When Navy-Marine Corps Accused Plead Guilty to General Article (court-martial data)
- Article 134 (General Article): Court-Martial Data and Trends (court-martial data)
- Article 134 UCMJ: The General Article (law firm reference page)
- U.S. Sentencing Commission, Individual Offender Datafiles (source)
- Federal Judicial Center, Integrated Database (criminal defendants) (source)
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.