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What Happens to Navy-Marine Corps Junior Enlisted (E-1 to E-4) Facing Indecent Recording And Exposure Charges?

Junior enlisted sailors and Marines (E-1 to E-4) convicted of indecent recording or exposure under Article 120c received shorter confinement than in all Navy and Marine Corps Article 120c cases. The median confinement was 8 months, compared with 11 months.

Understanding Trends in Military Practice · 5 min read

Trends › By Offense › Article 120c › Junior Enlisted (E-1 to E-4)

Short answer: Junior enlisted sailors and Marines (E-1 to E-4) convicted of indecent recording or exposure under Article 120c received shorter confinement than in all Navy and Marine Corps Article 120c cases. The median confinement was 8 months, compared with 11 months. The records hold 67 such courts-martial from 2017–2025. Only 1 of 11 contested cases that reached a verdict ended in a full acquittal (9%), compared with 19%.

Based on 67 cases · 2017–2025 · Navy and Marine Corps records · data updated October 24, 2026

Shorter Confinement Than in All Article 120c Cases

Of 66 convictions, 60 included confinement. The median confinement was 8 months, lower than the 11 months for all Navy and Marine Corps Article 120c cases. A quarter of terms were 1.5 years or longer.

The largest difference is in long sentences. 19 of 66 convictions (29%) included confinement longer than one year, compared with 38% for all Article 120c cases. Terms of 5 years or more were 5% of convictions, compared with 13%. Terms of 6 months to 1 year were more common here: 36% compared with 31%. These are adjudged sentences, before any plea-agreement cap, clemency, or appeal. They cover every charge in the case.

Adjudged confinementConvictionsShare hereShare, all Navy and Marine Corps Article 120c cases
No confinement69%9%
Under 6 months1726%22%
6 months to 1 year2436%31%
More than 1 year, under 5 years1624%25%
5 years or more35%13%

Few Contested Cases and Few Full Acquittals

Navy and Marine Corps records before December 2020 often omit the plea, and 54 of 67 records list one. Of those, 43 were guilty pleas and 11 were not-guilty or mixed pleas. That makes 20% contested, compared with 30% for all Navy and Marine Corps Article 120c cases.

Of the 11 contested cases that reached a verdict, 1 ended in a full acquittal and 3 ended in a partial acquittal. A partial acquittal means not guilty of at least one charge or specification and guilty of another. The full-acquittal rate was 9%, compared with 19% for all Navy and Marine Corps Article 120c cases.

Punitive Discharges at About the Same Rate

Among 66 convicted enlisted members, 51 received a bad-conduct or dishonorable discharge (77%), about the same as the 78% for all Navy and Marine Corps Article 120c cases. 14 of those were dishonorable.

A sentence without a punitive discharge does not rule out a later administrative separation, which these records do not track. Most of the 51 were bad-conduct discharges, the less severe kind.

General and Special Courts-Martial

34 of 67 cases (51%) were general courts-martial, the level that can impose long confinement and a dishonorable discharge. The other 33 were special courts-martial, which cap confinement at one year.

The median confinement was 1.5 years at general courts-martial and 5 months at special courts-martial. The contested share was 15% at the general level and 26% at the special level. Since 2019, a special court-martial tried by a military judge alone is further capped at six months with no punitive discharge.

Other Charges in These Cases

Of the 67 cases, 51 charged at least one other article. Article 134 (general article) appeared in 19, Article 120 (sexual assault) in 16, Article 128 (assault) in 14, Article 80 (attempt) in 13, and Article 92 (orders violation) in 8.

One sentence covers all charges in a case. The confinement and discharge figures include these offenses.

Rank of the Accused

All 67 accused were junior enlisted. For all Navy and Marine Corps Article 120c cases, junior enlisted made up 58%. These records do not reliably show whether a judge or members decided guilt, so this post does not report it.

Year and Installation Counts

The cases were tried from February 2017 through December 2025: 4 in 2017, 11 in 2018, 8 in 2019, 10 in 2020, 12 in 2021, 7 in 2022, 3 in 2023, 3 in 2024, and 9 in 2025.

Camp Lejeune, North Carolina had 13 cases, Norfolk, Virginia had 12, Camp Pendleton, California had 9, Bremerton, Washington had 5, and Okinawa, Japan had 4. These five account for 64% of the 67. Larger installations try more cases of every kind, so a count alone does not show that a base has a problem.

Law Changes and Unrecorded Details

The Military Justice Act of 2016 took effect on January 1, 2019. It brought fixed panel sizes, judge-alone special courts-martial capped at six months with no punitive discharge, and written plea agreements. Cases with offenses from before 2019 kept the old rules. Article 120c is a covered offense. Since December 28, 2023, special trial counsel decide whether to prosecute it. Judges sentence within new parameters when every guilty finding is for an offense after December 27, 2023.

The records give trial dates, not offense dates, so these rules cannot be matched to individual cases. The records also do not include conduct handled outside a court-martial, the evidence, or the plea terms.

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.

How We Counted

Navy and Marine Corps courts-martial tried 2017–2025 that charged junior enlisted members (E-1 to E-4) under Article 120c (67 cases), compared with every Navy and Marine Corps Article 120c case.

Source: public court-martial records (Article 140a, UCMJ) in Military Trial Results, data updated October 24, 2026. Definitions, sources, and known gaps: how this data was built. Errors: content@bodiesburied.com.

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.

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