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# Navy-Marine Corps Courts-Martial With Article 120 and Article 134, 2021–2025
- URL: https://www.bodiesburied.com/trends/navy-marine-corps-article-120-and-article-134-charged-together/
- Published: 2026-10-30T06:56:51.000Z
- Updated: 2026-11-03T01:45:35.000Z
- Description: From 2021–2025, 22 Navy and Marine Corps courts-martial charged both Article 120 (sexual assault) and Article 134 (general article). Of the cases with a recorded plea, 45% were contested, compared with 62% in all Navy and Marine Corps Article 120 cases.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 120, Article 134, Navy-Marine Corps

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 120](https://www.bodiesburied.com/trends/article-120-courts-martial/) › Navy-Marine Corps, with Article 134

**Short answer:** From 2021–2025, 22 Navy and Marine Corps courts-martial charged both Article 120 (sexual assault) and Article 134 (general article). Of the cases with a recorded plea, 45% were contested, compared with 62% in all Navy and Marine Corps Article 120 cases. A punitive discharge followed 60% of enlisted convictions, compared with 77% across those Article 120 cases.

Based on 22 cases · 2021–2025 · Navy and Marine Corps records · data updated October 24, 2026

## Guilty Pleas Were More Common

The plea is listed in 20 of the 22 records. In 11 of those, the accused pleaded guilty. In 9, the accused contested at least one charge by pleading not guilty to it.

The contested share was 45%. In all Navy and Marine Corps Article 120 cases, it was 62%.

## Fewer Punitive Discharges

Among the 15 enlisted members convicted, 9 received a bad-conduct or dishonorable discharge (60%). Of those 9, 4 were dishonorable discharges.

Across all Navy and Marine Corps Article 120 cases, 77% of convicted enlisted members received a punitive discharge. A sentence without one does not rule out a later administrative separation.

## Confinement Matched the Service Median

In 16 cases, the accused was convicted of at least one charge. Confinement was part of 12 of those sentences (75%).

The median confinement was 1.1 years. That is the same as the 1.1 years median in all Navy and Marine Corps Article 120 cases in 2021–2025\. Among the sentences that included confinement, a quarter were 2.2 years or longer.

These are adjudged sentences, set at trial before any plea-agreement cap, clemency, or appeal. Each covers every charge in the case.

## What Else Was Charged?

Article 128 (assault) appeared in 10 of the 22 cases. Article 120c (indecent recording and exposure) appeared in 4, Article 112a (drug) in 3, and Article 120b (child sexual abuse) in 3.

Article 134 covers a range of conduct, so the records alone do not show which Article 134 offense was charged in each case.

## Trials per Year

The cases were tried from February 2021 through August 2025\. There were 10 in 2021, 3 in 2022, 3 in 2023, 1 in 2024, and 5 in 2025.

## Rank and Court Level

Junior enlisted members (E-1 to E-4) were 65% of the accused, and NCOs were 35%. No officers appear. In all Navy and Marine Corps Article 120 cases, junior enlisted members were 64%.

General courts-martial heard 18 of the 22 cases (82%). A general court-martial can impose any lawful sentence, including long confinement and a dishonorable discharge. Special courts-martial heard the rest; they cap confinement at one year and cannot impose a dishonorable discharge.

## Rule Changes From December 2023

Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute covered offenses. Article 120 is a covered offense.

When every guilty finding in a case is for an offense after December 27, 2023, the military judge sets the sentence under new sentencing parameters. Both rules depend on the offense date. The records give only trial dates, so trials from 2024 on include cases under both the old and the new rules.

## Limits of the Records

The records cover only cases that reached a court-martial. Nonjudicial punishment, administrative separation, and cases with no action do not appear. The records do not describe the evidence or the plea terms.

For what the offense covers and how it is defended, see [Article 120 on the law firm's website](https://www.ucmj-defender.com/ucmj/article-120-sexual-assault/?ref=bodiesburied.com). Dates and sources for the law changes: [UCMJ change timeline](https://www.bodiesburied.com/trends/ucmj-change-timeline/).

### How We Counted

Navy and Marine Corps courts-martial with trial dates in 2021–2025 that charged both Article 120 and Article 134 (22 cases), compared with all 208 Navy and Marine Corps Article 120 cases in those years.

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 120 (Rape and Sexual Assault): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-120-courts-martial/) (hub)
- [Article 134 (General Article): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-134-courts-martial/) (hub)
- [Navy-Marine Corps Courts-Martial: Data and Trends](https://www.bodiesburied.com/trends/navy-marine-corps-courts-martial/) (hub)
- [Navy-Marine Corps Courts-Martial With Article 120 and Article 128, 2021–2026](https://www.bodiesburied.com/trends/navy-marine-corps-article-120-and-article-128-charged-together/)
- [Navy-Marine Corps Courts-Martial With Article 120 and Article 92, 2021–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-120-and-article-92-charged-together/)
- [Army Cases Charging Both Article 120 and Article 120c](https://www.bodiesburied.com/trends/army-article-120-and-article-120c-charged-together/)
- [Army Cases Charging Both Article 120 and Article 90](https://www.bodiesburied.com/trends/army-article-120-and-article-90-charged-together/)
- [Army Cases Charging Both Article 120 and Article 93](https://www.bodiesburied.com/trends/army-article-120-and-article-93-charged-together/)
- [Army Courts-Martial With Article 120 and Article 128, 2021–2026](https://www.bodiesburied.com/trends/army-article-120-and-article-128-charged-together/)
- [Army Courts-Martial With Article 120 and Article 128b, 2021–2026](https://www.bodiesburied.com/trends/army-article-120-and-article-128b-charged-together/)
- [Article 120 explained on the law firm's website](https://www.ucmj-defender.com/ucmj/article-120-sexual-assault/?ref=bodiesburied.com)
- [Search every case in Military Trial Results](https://www.bodiesburied.com/military-trial-results/) (members)

**Compare: federal court.** [Sexual Abuse of an Adult: Federal Cases vs. Article 120 Courts-Martial](https://www.bodiesburied.com/trends/federal-sexual-abuse-adult-vs-article-120/)

**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.