Theft and Fraud: Courts-Martial at San Diego vs. Federal Court in the Southern District of California
Courts-martial at San Diego, California produced 41 convictions for larceny, theft, and fraud under Article 121 from 2016 to 2025, and 26 of them (63%) included confinement, with a median of 8 months. In the Southern District of California, 700 of the 887 people sentenced under federal guideline §2B
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In brief: Courts-martial at San Diego, California produced 41 convictions for larceny, theft, and fraud under Article 121 from 2016 to 2025, and 26 of them (63%) included confinement, with a median of 8 months. In the Southern District of California, 700 of the 887 people sentenced under federal guideline §2B1.1 in fiscal years 2016 to 2025 (79%) received a prison term, and the median was 12.7 months. The federal group is the whole district's caseload for this guideline, not a count of military cases.
This post uses the U.S. Sentencing Commission's records of 887 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 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.
Confinement Was Less Common at San Diego
Confinement was part of 26 of the 41 San Diego sentences, or 63%. In the district court, 79% of those sentenced received a prison term. A quarter of the San Diego group received 12 months of confinement or more.
The San Diego median of 8 months is higher than the 5-month median for all 626 court-martial convictions for this offense in the data. The district median of 12.7 months is lower than the median for all federal districts, 21 months, across 53,639 people.
| Courts-martial at San Diego | Federal court, Southern District of California | |
|---|---|---|
| Convictions or people sentenced | 41 | 887 |
| Sentenced to confinement or prison | 63% | 79% |
| Median confinement or prison | 8 months | 12.7 months |
| A quarter received this or more | 12 months | 24 months |
| Pleaded guilty | 35 of 41 with a plea recorded (85%) | 97% |
| Mandatory minimum applied | See the caveats | 26 of 887 with the information (3%) |
Who Each Count Includes
The court-martial records list the trial location as "Marine Corps Recruit Depot San Diego", "San Diego", "San Diego California", or "San Diego, California". Of the 41 convictions, 38 were Navy cases and 3 were Marine Corps cases.
San Diego is within the Southern District of California. The 887 federal sentences come from across that district and are not cases from any installation. Most of the people sentenced were not service members, and the records do not suggest the San Diego courts-martial would have gone to federal court.
Guilty Pleas and Contested Convictions
Of the 41 San Diego convictions, 35 (85%) were guilty pleas. The 23 guilty-plea cases with confinement had a median of 9 months. The 3 contested cases with confinement had a median of 2.8 months, a figure based on very few sentences.
In the federal district, 861 people (97%) pleaded guilty and 26 were convicted after a trial. The median prison term after trial was 37 months, based on 23 people sent to prison, while the guilty-plea median was 12 months. More than 99% of the federal guilty pleas had a written plea agreement.
Discharges, Court Level, and Trial Years
Of the 41 enlisted members convicted, 23 (56%) received a punitive discharge, including 3 dishonorable discharges and 20 bad-conduct discharges. A general court-martial heard 10 of the 41 cases (24%).
The median confinement was 8 months for trials in 2016 to 2019 (15 cases with confinement) and 8 months for trials in 2020 to 2025 (11 cases).
Federal Sentencing Details
Probation only was ordered for 142 federal defendants (16%). Among those sent to prison, a quarter received 5 months or less, and a quarter received 24 months or more. A mandatory minimum applied to 26 people (3%).
Against the guideline range, 40% (351) were below it at the government's request, 38% (334) were within it, 15% (130) were above it, and 8% (72) were below it without a government request.
Restitution was ordered for 447 (50%), a fine for 64 (7%), and supervised release for 676 (76%), with a median supervised release term of 36 months.
Things the Records Do Not Show
Court-martial confinement is measured as adjudged, before clemency or appeal. Federal prison terms are measured as imposed, not served. Court-martial years go by trial date, while federal fiscal years begin October 1.
Federal records place 76% of the district's defendants in criminal history category I and 5% in category VI. Court-martial records have no criminal history field. The data also do not include the amount of loss in the San Diego cases or why each sentence was chosen.
How We Counted
Courts-martial with trial dates in 2016 to 2025 whose recorded trial location is San Diego, California, ending in a conviction for larceny, theft, and fraud (Article 121; federal guideline §2B1.1) (41). Federal: people sentenced in fiscal years 2016 to 2025 in the Southern District of California (U.S. Sentencing Commission district label "California South") under primary guideline §2B1.1 (theft, embezzlement, fraud, and property damage) (887). 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 (the background article)
- Federal Prosecution Analysis (all federal posts)
- How the Federal Comparison Data Was Built (sources and method)
- Theft and Fraud by Dollar Loss: Federal Sentences vs. Article 121 Courts-Martial (overview)
- Federal Sentences in the Southern District of California, FY2016–2025 (the federal district)
- Child Pornography: Courts-Martial at San Diego vs. Federal Court in the Southern District of California (same installation)
- Child Sexual Abuse and Enticement: Courts-Martial at San Diego vs. Federal Court in the Southern District of California (same installation)
- Drug Possession: Courts-Martial at San Diego vs. Federal Court in the Southern District of California (same installation)
- Drug Use: Courts-Martial at San Diego vs. Federal Court in the Southern District of California (same installation)
- Drug Distribution: Courts-Martial at San Diego vs. Federal Court in the Southern District of California (same installation)
- Obstruction of Justice: Courts-Martial at San Diego vs. Federal Court in the Southern District of California (same installation)
- Theft and Fraud: Courts-Martial at Bremerton vs. Federal Court in the Western District of Washington (other installations)
- Theft and Fraud: Courts-Martial at Camp Lejeune vs. Federal Court in the Eastern District of North Carolina (other installations)
- Theft and Fraud: Courts-Martial at Camp Pendleton vs. Federal Court in the Southern District of California (other installations)
- Theft and Fraud: Courts-Martial at Fort Hood vs. Federal Court in the Western District of Texas (other installations)
- Theft and Fraud: Federal Sentences vs. Air Force Courts-Martial, 2016–2025
- Theft and Fraud: Federal Sentences vs. Army Courts-Martial
- Theft and Fraud: Federal Sentences vs. Marine Corps Courts-Martial
- Army Article 121 Cases by the Numbers, 2021–2025 (court-martial data)
- Article 121 Sentences in the Army: Confinement and Discharges, 2021–2025 (court-martial data)
- Fighting an Army Larceny Charge: How Contested Cases Ended (court-martial data)
- Guilty Pleas in Army Larceny Cases: How Often, and What Came Next (court-martial data)
- Air Force Article 121 Cases by the Numbers, 2016–2025 (court-martial data)
- What Sentence Follows an Air Force Larceny Conviction? (court-martial data)
- Pleading Guilty to Article 121 in the Air Force: What Sentences Followed? (court-martial data)
- How Has Article 121 Changed in Navy-Marine Corps Courts-Martial Since 2017? (court-martial data)
- Article 121 Sentences in the Navy-Marine Corps: Confinement and Discharges, 2017–2025 (court-martial data)
- Not Guilty Pleas in Navy-Marine Corps Article 121 Cases: What Happened at Trial (court-martial data)
- Guilty Pleas in Navy-Marine Corps Larceny Cases: How Often, and What Came Next (court-martial data)
- Article 121 (Larceny): Court-Martial Data and Trends (court-martial data)
- Article 121 UCMJ: Larceny and Wrongful Appropriation (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.