> ## Content Index
> Fetch the complete content index at: https://www.bodiesburied.com/llms.txt
> Use this file to discover other available public pages before exploring further.

# Stealing From the Government: 18 U.S.C. 641 and False Claims vs. Articles 121 and 124
- URL: https://www.bodiesburied.com/trends/federal-theft-government-property-false-claims-vs-articles-121-124/
- Published: 2026-11-03T01:37:45.000Z
- Updated: 2026-11-03T01:37:45.000Z
- Description: Federal prosecutors charged 9,190 defendants under 18 U.S.C. 641 (theft of government money or property) in cases that ended in fiscal years 2016 to 2025. 6,127 (67%) pleaded guilty, and 38 of the 164 who went to trial were acquitted (23%). Courts-martial recorded 259 Article 121 convictions that me
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Federal

[Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › Stealing From the Government

**In brief:** Federal prosecutors charged 9,190 defendants under 18 U.S.C. 641 (theft of government money or property) in cases that ended in fiscal years 2016 to 2025\. 6,127 (67%) pleaded guilty, and 38 of the 164 who went to trial were acquitted (23%). Courts-martial recorded 259 Article 121 convictions that mention military or government property and 17 Article 124 convictions.

Updated November 2, 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 437 people sentenced in federal court in fiscal years 2016 to 2025 and the Federal Judicial Center's records of 9,676 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](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/).

## How Federal Theft of Government Property Cases Ended

The Federal Judicial Center counts every defendant whose case ended, including dismissals and acquittals. For 18 U.S.C. 641, that was 9,190 defendants in fiscal years 2016 to 2025.

6,127 (67%) pleaded guilty, 2,899 (32%) had their cases dismissed, and 164 (2%) went to trial. In all, 6,253 of the 9,190 (68%) were convicted, by plea or at trial.

Of the 164 trials, 38 ended in an acquittal (23%). There were 137 jury trials with 26 acquittals (19%), and 27 bench trials, decided by a judge, with 12 acquittals (44%).

| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| ----------- | ----------- | -------------- | --------- | ------ | ------------------ |
| 2016        | 1,651       | 65%            | 33%       | 30     | 9 (30%)            |
| 2017        | 1,333       | 66%            | 32%       | 27     | 4 (15%)            |
| 2018        | 1,116       | 65%            | 32%       | 31     | 4 (13%)            |
| 2019        | 1,076       | 66%            | 33%       | 17     | 7 (41%)            |
| 2020        | 795         | 62%            | 36%       | 11     | 2 (18%)            |
| 2021        | 763         | 68%            | 31%       | 7      | 3 (3 of 7)         |
| 2022        | 706         | 73%            | 26%       | 11     | 3 (27%)            |
| 2023        | 668         | 69%            | 29%       | 14     | 2 (14%)            |
| 2024        | 547         | 65%            | 33%       | 13     | 2 (15%)            |
| 2025        | 535         | 73%            | 26%       | 3      | 2 (2 of 3)         |

## False Claims Under 18 U.S.C. 287

A false claim against the United States is charged under 18 U.S.C. 287\. The Federal Judicial Center records 486 defendants whose cases ended in fiscal years 2016 to 2025 with that statute as the most serious charge.

418 (86%) pleaded guilty, 42 (9%) had their cases dismissed, and 26 (5%) went to trial. 441 of the 486 (91%) were convicted. Of the 26 trials, 3 ended in an acquittal (12%).

These are small numbers. The 25 jury trials had 2 acquittals (8%), and the 1 bench trial ended in an acquittal.

## Sentences in Federal False Claims Cases

The U.S. Sentencing Commission counts people who were sentenced, which is a narrower group than defendants whose cases ended. It lists 437 people sentenced for false claims under guideline §2B1.1 with 18 U.S.C. 287.

314 of the 437 (72%) received a prison term, and 94 (22%) received probation only. The median prison term was 27 months (2.2 years). A quarter received 48 months or more, and a quarter received 10.9 months or less.

378 of 437 (86%) pleaded guilty, and 59 were convicted after a trial.

## What Courts-Martial Recorded Under Article 121

Court-martial records list 259 larceny convictions where the charge description mentions military or government property. These have trial dates from 2016 to 2025\. By service, there were 52 in the Army, 115 in the Air Force, 39 in the Navy, and 53 in the Marine Corps.

202 of the convictions with a sentence recorded (78%) included confinement. The median adjudged confinement was 3.8 months, and a quarter received 8 months or more.

Of the 244 enlisted members convicted, 138 received a punitive discharge (57%). That count includes 16 dishonorable discharges and 122 bad-conduct discharges. Officers convicted numbered 14, and 7 were dismissed.

## What Courts-Martial Recorded Under Article 124

Article 124 covers frauds against the United States. It replaced the former Article 132 on January 1, 2019, so the court-martial records start in 2019 and the 17 convictions have trial dates from 2020 to 2025\. By service, there were 7 in the Army, 5 in the Air Force, 4 in the Navy, and 1 in the Marine Corps.

9 of the 17 convictions with a sentence recorded (53%) included confinement. The median adjudged confinement was 3.9 months, and a quarter received 5 months or more.

Of the 13 enlisted members convicted, 4 received a punitive discharge (31%), all bad-conduct discharges. Officers convicted numbered 3, and 1 was dismissed. A general court-martial heard 7 of the 17 convictions (41%).

## What This Comparison Can and Cannot Show

The federal and court-martial sides count different things. The federal case counts include dismissals and acquittals, and the Sentencing Commission counts include only people who were sentenced. The court-martial counts include only convictions.

For that reason, the records here do not give an acquittal rate for courts-martial under these articles. Trials were uncommon in both federal charge groups. The federal acquittal rates also rest on small numbers of trials, and a year with 3 trials, such as fiscal year 2025, cannot support a trend.

Court-martial sentences are as adjudged at trial, before any clemency or appeal. The records cannot show the facts of any case or why a case ended as it did.

### How We Counted

Federal: defendants whose cases ended in fiscal years 2016 to 2025 with 18 U.S.C. 641 (9,190) or 18 U.S.C. 287 (486) as the most serious charge (Federal Judicial Center), and people sentenced for false claims (437, U.S. Sentencing Commission). Courts-martial: Article 124 convictions from 2019 (17) and Article 121 convictions whose description mentions military or government property (259).

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.

**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.

**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)
- [Guilty Pleas in False Claims Against the United States Cases: Federal Court vs. Courts-Martial](https://www.bodiesburied.com/trends/federal-false-claims-guilty-plea-rate-vs-courts-martial/)
- [False Claims Against the United States Sentences: Federal Court vs. Courts-Martial, 2016–2025](https://www.bodiesburied.com/trends/federal-false-claims-sentences-vs-courts-martial/)
- [Are Courts-Martial More Likely to End in Acquittal Than Federal Trials?](https://www.bodiesburied.com/trends/federal-trial-acquittal-rates-vs-courts-martial/)
- [Guilty Pleas in Federal Court vs. Courts-Martial, Year by Year](https://www.bodiesburied.com/trends/federal-guilty-plea-rates-vs-courts-martial/)
- [Child Pornography Sentences: Federal Court vs. Courts-Martial, 2016–2025](https://www.bodiesburied.com/trends/federal-child-pornography-sentences-vs-courts-martial/)
- [Federal Law Has No Crime of Drug Use: How Article 112a Cases Compare](https://www.bodiesburied.com/trends/federal-no-crime-of-drug-use-article-112a/)
- [Drug Distribution and Importation: Federal vs. Court-Martial Sentences, 2016–2025](https://www.bodiesburied.com/trends/federal-drug-distribution-importation-vs-article-112a/)
- [Sexual Abuse of an Adult: Federal Cases vs. Article 120 Courts-Martial](https://www.bodiesburied.com/trends/federal-sexual-abuse-adult-vs-article-120/)
- [Child Sexual Abuse and Enticement: Federal Cases vs. Article 120b Courts-Martial](https://www.bodiesburied.com/trends/federal-child-sexual-abuse-enticement-vs-article-120b/)
- [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/)
- [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)
- [Article 124 UCMJ: Frauds Against the United States](https://www.ucmj-defender.com/practice-areas/court-martial/article-124/?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.