Not Guilty Pleas in Navy-Marine Corps Article 120c Cases: What Happened at Trial

Trends › By Offense › Article 120c › Not Guilty Pleas in Navy-Marine Corps Ar

Based on 27 cases · 2017–2025 · Navy and Marine Corps records · data updated October 24, 2026

Most Convictions Included a Punitive Discharge

Article 120c covers offenses such as indecent recording, broadcasting, and exposure. In the 27 contested Navy and Marine Corps courts-martial that included it from September 2017 to July 2025, 79% of enlisted convictions included a punitive discharge: 9 bad-conduct discharges and 6 dishonorable discharges. The rate for all contested Navy and Marine Corps cases was 50%.

Both of the 2 convicted officers or warrant officers were dismissed. Dismissal is the officer equivalent of a punitive discharge. A sentence without a punitive discharge does not rule out a later administrative separation.

Fewer Full Acquittals Than in All Contested Cases

Every case here was contested, meaning the accused pleaded not guilty to at least one charge. There were 0 guilty pleas. Of the 27, 5 ended in a full acquittal (19%), compared with 31% for all contested Navy and Marine Corps cases.

Another 7 (26%) ended in a partial acquittal: not guilty of at least one charge or specification and guilty of another. The rest ended in a conviction on every contested charge.

Length of Confinement

86% of the 22 convictions included confinement. The median confinement was 7 months, the same as the 7-month median for all contested Navy and Marine Corps cases.

Long sentences were more common than in all contested cases. 8 of 22 convictions (36%) included confinement longer than one year, compared with 24% for all contested Navy and Marine Corps cases. 3 (14%) included 5 years or more, compared with 8%. Only 3 convictions (14%) had no confinement, compared with 34% for all contested cases. Terms of 6 months to 1 year were also more common here: 27% compared with 14%. These are adjudged sentences, before any plea-agreement cap, clemency, or appeal. They cover every charge in the case.

General and Special Courts-Martial

17 of the 27 cases (63%) were general courts-martial, compared with 53% for all contested Navy and Marine Corps cases. At general courts-martial, 85% of convictions included confinement, and the median confinement was 3 years.

At the 10 special courts-martial, 8 of 9 convictions included confinement, and the median was 5 months. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge. A general court-martial can impose any lawful sentence.

Often Charged With Sexual Assault

Article 120c was the only charge in 5 of 27 cases. Article 120 (sexual assault) was also charged in 10, Article 134 (general article) and Article 128 (assault) in 6 each, Article 80 (attempt) in 5, and Article 92 (orders violation) in 3.

An adjudged sentence covers all charges, so the terms above include those other convictions too. The records do not split a sentence by charge, so they cannot show how much of any term related to a recording or exposure count. That limit matters most in the 10 cases that also charged sexual assault.

Rank and Location

Among the accused with rank recorded, 11 were junior enlisted, 13 were NCOs, and 2 were officers. This group is more senior than all contested Navy and Marine Corps cases.

Bremerton, Washington had the most of these cases with 6. Camp Pendleton, California and Norfolk, Virginia had 3 each, and San Diego, California and Camp Lejeune, North Carolina had 2 each. Together these five account for 59% of the 27. Larger installations try more cases of every kind.

A Small Number of Cases Each Year

No year had more than 5 cases: 2 in 2017, 3 in 2018, 3 in 2019, 4 in 2020, 5 in 2021, 4 in 2022, 1 in 2023, 2 in 2024, and 3 in 2025. With counts this low, a single case changes any percentage on this page by a noticeable amount.

Navy and Marine Corps records before December 2020 often omit the plea and forum, and contested counts here use only the records that list them.

Law Changes and Limits

Article 120c is a covered offense. Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute covered offenses. When every guilty finding in a case is for an offense after December 27, 2023, the military judge sets the sentence within new parameters. The records give trial dates, not offense dates, so trials from 2024 on include cases under both old and new rules.

The records also do not describe the evidence or plea terms. Cases handled by nonjudicial punishment or administrative separation do not appear.

For what the offense covers and how it is defended, see Article 120c on the law firm's website. Dates and sources for the law changes: UCMJ change timeline.

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.