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# Theft and Fraud: Courts-Martial at Norfolk vs. Federal Court in the Eastern District of Virginia
- URL: https://www.bodiesburied.com/trends/federal-theft-fraud-norfolk-vs-eastern-district-of-virginia/
- Published: 2026-11-03T06:10:58.000Z
- Updated: 2026-11-03T06:10:58.000Z
- Description: Of the 28 Navy convictions for larceny, theft, and fraud under Article 121 at Norfolk, Virginia from 2016 to 2025, 27 (96%) were guilty pleas, and the median adjudged confinement was 6 months. In the Eastern District of Virginia, 1,240 people were sentenced under federal guideline §2B1.1 in fiscal y
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Federal

[Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › [Theft and Fraud by Dollar Loss](https://www.bodiesburied.com/trends/federal-theft-fraud-dollar-loss-vs-article-121/) › Theft and Fraud: Norfolk

**In brief:** Of the 28 Navy convictions for larceny, theft, and fraud under Article 121 at Norfolk, Virginia from 2016 to 2025, 27 (96%) were guilty pleas, and the median adjudged confinement was 6 months. In the Eastern District of Virginia, 1,240 people were sentenced under federal guideline §2B1.1 in fiscal years 2016 to 2025, and the median prison term was 30 months (2.5 years). The federal count comes from the full district and is mostly made up of people who were not in the military.

Updated November 3, 2026 · Sources: U.S. Sentencing Commission and Federal Judicial Center, fiscal years 2016–2025 · Military Trial Results

This post uses the U.S. Sentencing Commission's records of 1,240 people sentenced in federal court in fiscal years 2016 to 2025, compared with court-martial results from this site's Military Trial Results data (updated November 2, 2026). Acquittals and dismissals come from a second source, the Federal Judicial Center's records of 753,808 federal defendants whose cases ended in fiscal years 2016 to 2025\. It is part of the [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) series, which builds on [Military Moves Toward Sentencing Guidelines to Mirror the Federal System](https://www.bodiesburied.com/trends/military-sentencing-guidelines-federal-system/). How the numbers were built: [How the Federal Comparison Data Was Built](https://www.bodiesburied.com/trends/federal-data-methodology/).

## Nearly Every Norfolk Case Was a Guilty Plea

At Norfolk, only 1 of the 28 convictions came after a contested trial. That case included 8 months of confinement. The 21 guilty-plea cases with confinement had a median of 6 months.

Federal court in the district showed a similar reliance on pleas. Of the 1,240 people sentenced, 1,182 (95%) pleaded guilty, and 97% of those pleas came with a written plea agreement. The other 3% were straight pleas.

The 58 federal defendants convicted at trial had longer terms. Their median prison term was 63 months, based on 56 people sent to prison, compared with 30 months after a guilty plea.

## Which Records Are Included

The court-martial side counts convictions where the records list the trial location as "Norfolk" or "Norfolk, Virginia". All 28 were Navy cases.

Norfolk is in the Eastern District of Virginia, but the federal side is not a count of Norfolk military cases. It includes every person sentenced under this guideline in the district, and most of them were civilians. Courts-martial are tried in military courts, not in the district court.

|                                    | Courts-martial at Norfolk           | Federal court, Eastern District of Virginia |
| ---------------------------------- | ----------------------------------- | ------------------------------------------- |
| Convictions or people sentenced    | 28                                  | 1,240                                       |
| Sentenced to confinement or prison | 79%                                 | 85%                                         |
| Median confinement or prison       | 6 months                            | 30 months                                   |
| A quarter received this or more    | 8.7 months                          | 54 months                                   |
| Pleaded guilty                     | 27 of 28 with a plea recorded (96%) | 95%                                         |
| Mandatory minimum applied          | See the caveats                     | 230 of 1,238 with the information (19%)     |

## Confinement and Discharges at Norfolk

Confinement was included in 22 of the 28 sentences (79%). A quarter received 8.7 months or more. The 6-month median is higher than the 5-month median for all 626 court-martial convictions for this offense in the data.

Of the 27 enlisted sailors convicted, 17 (63%) received a punitive discharge: 2 dishonorable discharges and 15 bad-conduct discharges. The records also show 1 officer convicted, who was not dismissed. A general court-martial heard 7 of the 28 cases (25%).

For trials in 2016 to 2019, the median was 6.5 months across 18 cases with confinement. For trials in 2020 to 2025, it was 4.5 months across 4 cases, a small group.

## What Else Federal Judges Ordered

Restitution was ordered for 1,112 of the federal defendants (90%). Supervised release after prison was ordered for 1,047 (84%), with a median term of 36 months. A fine was ordered for 58 (5%).

Prison was imposed on 1,058 people (85%), and 98 (8%) received probation only. A quarter of the prison terms were 54 months or more, and a quarter were 12 months or less. The district median of 30 months was higher than the 21-month median across all federal districts, which sentenced 53,639 people.

## The Guideline Range in the Eastern District of Virginia

Federal sentences start from a recommended guideline range. Here, 43% (531) were within the range and 38% (471) were below it without a government request. Another 16% (194) were below it at the government's request, and 4% (44) were above it.

A mandatory minimum prison term applied to 230 people (19%).

## What the Data Cannot Answer

Court-martial terms are counted as adjudged, before clemency or appeal. Federal terms are counted as imposed, not as served. The court-martial years are by trial date, and federal fiscal years run from October 1 to September 30.

Federal records place 66% of the district's defendants in criminal history category I and 4% in category VI, but court-martial records have no such field. Neither set of records shows the facts of a case, the amount taken, or the reasons for any sentence.

### How We Counted

Courts-martial with trial dates in 2016 to 2025 whose recorded trial location is Norfolk, Virginia, ending in a conviction for larceny, theft, and fraud (Article 121; federal guideline §2B1.1) (28). Federal: people sentenced in fiscal years 2016 to 2025 in the Eastern District of Virginia (U.S. Sentencing Commission district label "Virginia East") under primary guideline §2B1.1 (theft, embezzlement, fraud, and property damage) (1,240). The installation is matched to the federal district for the county where it sits.

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.

**No parole in federal prison; credit for good conduct.** Federal prison has no parole for crimes committed on or after November 1, 1987\. A federal prisoner can earn up to 54 days of good conduct credit for each year of the sentence the judge imposed, which is about 15%. Some federal prisoners can also earn First Step Act time credits, but many offenses make a person ineligible. The numbers in this post are the sentences judges imposed, not the time people actually served.

**Military confinement credit and parole.** For military sentences adjudged after 2004, good conduct time is 5 days for each month of confinement, about 16%. Military prisoners can also earn up to 8 more days a month for work and programs and up to 2 days a month for special acts, with a limit of 15 days a month in total. Military prisoners can be considered for parole by their service's clemency and parole board. The military numbers in this post are the confinement adjudged at trial, not the time served.

**Military sentences include punishments federal sentences do not.** A court-martial sentence can include a punitive discharge (bad-conduct discharge, dishonorable discharge, or dismissal for officers), reduction in rank, and forfeiture of pay. These have no federal counterpart. A comparison of months of confinement leaves them out. A short confinement term combined with a dishonorable discharge is a heavier sentence than the months alone show.

**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.

## Related Analysis

- [Military Moves Toward Sentencing Guidelines to Mirror the Federal System](https://www.bodiesburied.com/trends/military-sentencing-guidelines-federal-system/) (the background article)
- [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) (all federal posts)
- [How the Federal Comparison Data Was Built](https://www.bodiesburied.com/trends/federal-data-methodology/) (sources and method)
- [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/) (overview)
- [Federal Sentences in the Eastern District of Virginia, FY2016–2025](https://www.bodiesburied.com/trends/federal-district-eastern-district-of-virginia/) (the federal district)
- [Child Sexual Abuse and Enticement: Courts-Martial at Norfolk vs. Federal Court in the Eastern District of Virginia](https://www.bodiesburied.com/trends/federal-child-sex-offenses-norfolk-vs-eastern-district-of-virginia/) (same installation)
- [Drug Use: Courts-Martial at Norfolk vs. Federal Court in the Eastern District of Virginia](https://www.bodiesburied.com/trends/federal-drug-use-norfolk-vs-eastern-district-of-virginia/) (same installation)
- [Drug Distribution: Courts-Martial at Norfolk vs. Federal Court in the Eastern District of Virginia](https://www.bodiesburied.com/trends/federal-drug-distribution-norfolk-vs-eastern-district-of-virginia/) (same installation)
- [Obstruction of Justice: Courts-Martial at Norfolk vs. Federal Court in the Eastern District of Virginia](https://www.bodiesburied.com/trends/federal-obstruction-norfolk-vs-eastern-district-of-virginia/) (same installation)
- [Theft and Fraud: Courts-Martial at Bremerton vs. Federal Court in the Western District of Washington](https://www.bodiesburied.com/trends/federal-theft-fraud-bremerton-vs-western-district-of-washington/) (other installations)
- [Theft and Fraud: Courts-Martial at Camp Lejeune vs. Federal Court in the Eastern District of North Carolina](https://www.bodiesburied.com/trends/federal-theft-fraud-camp-lejeune-vs-eastern-district-of-north-carolina/) (other installations)
- [Theft and Fraud: Courts-Martial at Camp Pendleton vs. Federal Court in the Southern District of California](https://www.bodiesburied.com/trends/federal-theft-fraud-camp-pendleton-vs-southern-district-of-california/) (other installations)
- [Theft and Fraud: Courts-Martial at Fort Hood vs. Federal Court in the Western District of Texas](https://www.bodiesburied.com/trends/federal-theft-fraud-fort-hood-vs-western-district-of-texas/) (other installations)
- [Theft and Fraud: Federal Sentences vs. Air Force Courts-Martial, 2016–2025](https://www.bodiesburied.com/trends/federal-theft-fraud-vs-air-force/)
- [Theft and Fraud: Federal Sentences vs. Army Courts-Martial](https://www.bodiesburied.com/trends/federal-theft-fraud-vs-army/)
- [Theft and Fraud: Federal Sentences vs. Marine Corps Courts-Martial](https://www.bodiesburied.com/trends/federal-theft-fraud-vs-marine-corps/)
- [Army Article 121 Cases by the Numbers, 2021–2025](https://www.bodiesburied.com/trends/army-article-121-trend-2021-2025/) (court-martial data)
- [Article 121 Sentences in the Army: Confinement and Discharges, 2021–2025](https://www.bodiesburied.com/trends/army-article-121-sent-2021-2025/) (court-martial data)
- [Fighting an Army Larceny Charge: How Contested Cases Ended](https://www.bodiesburied.com/trends/army-article-121-acq-2021-2025/) (court-martial data)
- [Guilty Pleas in Army Larceny Cases: How Often, and What Came Next](https://www.bodiesburied.com/trends/army-article-121-plea-2021-2025/) (court-martial data)
- [Air Force Article 121 Cases by the Numbers, 2016–2025](https://www.bodiesburied.com/trends/air-force-article-121-trend-2016-2025/) (court-martial data)
- [What Sentence Follows an Air Force Larceny Conviction?](https://www.bodiesburied.com/trends/air-force-article-121-sent-2016-2025/) (court-martial data)
- [Pleading Guilty to Article 121 in the Air Force: What Sentences Followed?](https://www.bodiesburied.com/trends/air-force-article-121-plea-2016-2025/) (court-martial data)
- [How Has Article 121 Changed in Navy-Marine Corps Courts-Martial Since 2017?](https://www.bodiesburied.com/trends/navy-marine-corps-article-121-trend-2017-2025/) (court-martial data)
- [Article 121 Sentences in the Navy-Marine Corps: Confinement and Discharges, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-121-sent-2017-2025/) (court-martial data)
- [Not Guilty Pleas in Navy-Marine Corps Article 121 Cases: What Happened at Trial](https://www.bodiesburied.com/trends/navy-marine-corps-article-121-acq-2017-2025/) (court-martial data)
- [Guilty Pleas in Navy-Marine Corps Larceny Cases: How Often, and What Came Next](https://www.bodiesburied.com/trends/navy-marine-corps-article-121-plea-2017-2025/) (court-martial data)
- [Article 121 (Larceny): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-121-courts-martial/) (court-martial data)
- [Article 121 UCMJ: Larceny and Wrongful Appropriation](https://www.ucmj-defender.com/practice-areas/court-martial/article-121/?ref=bodiesburied.com) (law firm reference page)
- [U.S. Sentencing Commission, Individual Offender Datafiles](https://www.ussc.gov/research/datafiles/commission-datafiles?ref=bodiesburied.com) (source)
- [Federal Judicial Center, Integrated Database (criminal defendants)](https://www.fjc.gov/research/idb?ref=bodiesburied.com) (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](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.