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# Is Navy-Marine Corps Military Property Prosecution Rising or Falling? Article 108, 2017–2025
- URL: https://www.bodiesburied.com/trends/navy-marine-corps-article-108-trend-2017-2025/
- Published: 2026-10-28T06:33:12.000Z
- Updated: 2026-10-30T08:04:20.000Z
- Description: Navy and Marine Corps records show 24 courts-martial charging Article 108, the military property article. All of them were tried from February 2021 on, and the most in 1 year was 9 cases in 2021.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 108, Navy-Marine Corps

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 108](https://www.bodiesburied.com/trends/article-108-courts-martial/) › Navy-Marine Corps

**Short answer:** Navy and Marine Corps records show 24 courts-martial charging Article 108, the military property article. All of them were tried from February 2021 on, and the most in 1 year was 9 cases in 2021\. The median confinement was 9 months, compared with 6 months in the rest of the Navy and Marine Corps, and 52% of convicted enlisted members received a punitive discharge, compared with 62% service-wide.

Based on 24 cases · 2017–2025 · Navy and Marine Corps records · data updated October 24, 2026

## No Cases Before 2021

For 2017 through 2020, the records list 0 cases charging Article 108\. The first case is from February 2021\. There were 9 cases in 2021, 4 in 2022, 4 in 2023, 2 in 2024, and 5 in 2025\. The records cannot show why no earlier cases appear.

Navy and Marine Corps convictions that included Article 108, by year: 2017 0, 2018 0, 2019 0, 2020 0, 2021 9, 2022 4, 2023 4, 2024 2, 2025 5020170201802019020209202142022420232202452025

Navy and Marine Corps convictions that included Article 108, by year

## Share of Convictions by Year

Article 108 was part of 2% of Navy and Marine Corps convictions with offenses listed in 2021\. It was 1% in each year from 2022 through 2024 and 2% in 2025\. The 24 cases are 1% of the 3,740 Navy and Marine Corps courts-martial from 2017–2025.

With numbers this small, a few cases can change a single year's share. The figures show direction, not a firm trend.

| Year | Convictions incl. Art. 108 | All convictions with offenses listed | Share |
| ---- | -------------------------- | ------------------------------------ | ----- |
| 2017 | 0                          | 437                                  | 0%    |
| 2018 | 0                          | 433                                  | 0%    |
| 2019 | 0                          | 373                                  | 0%    |
| 2020 | 0                          | 354                                  | 0%    |
| 2021 | 9                          | 385                                  | 2%    |
| 2022 | 4                          | 322                                  | 1%    |
| 2023 | 4                          | 283                                  | 1%    |
| 2024 | 2                          | 345                                  | 1%    |
| 2025 | 5                          | 312                                  | 2%    |

## Usually Charged With Other Offenses

Larceny under Article 121 was the most common charge filed with Article 108, in 11 cases. Article 92 (orders violation) and Article 134 (general article) each appeared in 7, Article 128 (assault) in 5, and Article 80 (attempt) in 3\. Only 4 of the 24 cases charged Article 108 by itself.

Each adjudged sentence covers every charge in the case. A confinement sentence includes the larceny, assault, or other charges as well as the property offense.

## How Much Confinement?

All 24 cases ended in a conviction on at least one charge, and 17 of those sentences included confinement (71%). The median confinement was 9 months, longer than the 6 months across the whole Navy and Marine Corps. A quarter of the confinement sentences were 1.2 years or longer.

Convictions with no confinement were more common here: 29%, compared with 18% across the Navy and Marine Corps. Sentences under 6 months were less common: 21%, compared with 35%. Sentences of 6 months to 1 year were 25%, compared with 22%. Sentences of more than 1 year but under 5 years were 21%, compared with 18%.

In total, 6 of 24 convictions (25%) included more than one year, the same 25% as across the Navy and Marine Corps. These are adjudged sentences, set at trial before any plea-agreement cap, clemency, or appeal.

| Adjudged confinement            | Convictions | Share here | Share, all Navy and Marine Corps cases in those years |
| ------------------------------- | ----------- | ---------- | ----------------------------------------------------- |
| No confinement                  | 7           | 29%        | 18%                                                   |
| Under 6 months                  | 5           | 21%        | 35%                                                   |
| 6 months to 1 year              | 6           | 25%        | 22%                                                   |
| More than 1 year, under 5 years | 5           | 21%        | 18%                                                   |
| 5 years or more                 | 1           | 4%         | 7%                                                    |

## General and Special Courts-Martial

Here, 13 cases were special courts-martial and 11 (46%) were general courts-martial. The 13 special courts-martial had a median confinement of 3 months, and 23% were contested. The 11 general courts-martial had a median of 1.2 years, and 40% were contested.

A special court-martial caps confinement at one year and cannot impose a dishonorable discharge. A general court-martial can impose any lawful sentence, including long confinement and a dishonorable discharge.

## Pleas

Every case here was tried from 2021 on, and 23 of 24 list a plea. Navy and Marine Corps records before December 2020 often omit the plea, but that does not affect these cases.

A case is contested when the accused pleads not guilty to at least one charge. There were 16 guilty pleas and 7 not-guilty or mixed pleas. The contested share was 30%, a little lower than the 32% across Navy and Marine Corps cases in those years. All 24 cases ended in a conviction on at least one charge, including the 7 contested cases.

## Punitive Discharges for Enlisted Members

Across the whole Navy and Marine Corps, 62% of convicted enlisted members received a punitive discharge. Here, the share was lower: 12 of 23 (52%). Of those 12, 10 were bad-conduct discharges and 2 were dishonorable discharges. A sentence without a punitive discharge does not rule out a later administrative separation.

## Rank and Location

The accused were 12 NCOs, 11 junior enlisted members, and 0 officers. That group is more senior than the Navy and Marine Corps as a whole.

These 5 installations account for 79% of the 24 cases. Camp Lejeune, North Carolina tried 8\. San Diego, California tried 4 and Camp Pendleton, California tried 3\. Quantico, Virginia and Mayport, Florida tried 2 each. A high count alone does not mean a base has a problem with this offense, because larger installations try more cases of every kind.

## Law Changes and the Limits of the Data

The Military Justice Act of 2016 took effect on January 1, 2019\. It created judge-alone special courts-martial capped at six months with no punitive discharge and introduced written plea agreements. Since December 28, 2023, special trial counsel decide whether to prosecute covered offenses. When every guilty finding is for an offense after December 27, 2023, the military judge sets the sentence under new parameters. These changes overlap the years covered here. The records cannot show whether they caused any change.

Trial records list charges, pleas, findings, and sentences. They do not include the evidence, the plea terms, or conduct handled outside a court-martial. Navy and Marine Corps records before December 2020 often omit the plea and forum, and offense dates are not recorded.

Dates and sources for the law changes mentioned here: [UCMJ change timeline](https://www.bodiesburied.com/trends/ucmj-change-timeline/).

### How We Counted

Navy and Marine Corps courts-martial tried 2017–2025 that charged Article 108 (24 cases). The trend line uses convictions whose records list the offenses found, by trial year.

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 108 (Military Property; Loss, Damage, Destruction): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-108-courts-martial/) (hub)
- [Navy-Marine Corps Courts-Martial: Data and Trends](https://www.bodiesburied.com/trends/navy-marine-corps-courts-martial/) (hub)
- [By Offense](https://www.bodiesburied.com/trends/by-offense/) (hub)
- [Fewer or More? Military Property Charges at Army Courts-Martial, 2021–2025](https://www.bodiesburied.com/trends/army-article-108-trend-2021-2025/) (another service)
- [Fewer or More? Military Property Charges at Air Force Courts-Martial, 2016–2025](https://www.bodiesburied.com/trends/air-force-article-108-trend-2016-2025/) (another service)
- [Fewer or More? Attempt Charges at Navy-Marine Corps Courts-Martial, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-80-trend-2017-2025/)
- [Fewer or More? Child Endangerment Charges at Navy-Marine Corps Courts-Martial, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-119b-trend-2017-2025/)
- [Fewer or More? Child Sexual Abuse Charges at Navy-Marine Corps Courts-Martial, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-120b-trend-2017-2025/)
- [Article 108 Sentences in the Navy-Marine Corps: Confinement and Discharges, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-108-sent-2017-2025/)
- [Search every case in Military Trial Results](https://www.bodiesburied.com/military-trial-results/) (members)

**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.