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# Pleading Guilty to Article 120c in the Navy-Marine Corps: What Sentences Followed?
- URL: https://www.bodiesburied.com/trends/navy-marine-corps-article-120c-plea-2017-2025/
- Published: 2026-10-28T06:50:46.000Z
- Updated: 2026-10-30T08:04:58.000Z
- Description: In 63 Navy and Marine Corps courts-martial from 2017–2025 where the accused pleaded guilty to charges including Article 120c (indecent recording and exposure), the median adjudged confinement was 11 months. The median for all Navy and Marine Corps guilty pleas was 6 months.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 120c, Navy-Marine Corps

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 120c](https://www.bodiesburied.com/trends/article-120c-courts-martial/) › Pleading Guilty to Article 120c in the N

**Short answer:** In 63 Navy and Marine Corps courts-martial from 2017–2025 where the accused pleaded guilty to charges including Article 120c (indecent recording and exposure), the median adjudged confinement was 11 months. The median for all Navy and Marine Corps guilty pleas was 6 months. 69% of convicted enlisted members received a punitive discharge, compared with 60% for all Navy and Marine Corps guilty pleas.

Based on 63 cases · 2017–2025 · Navy and Marine Corps records · data updated October 24, 2026

## Most Guilty Pleas Included Confinement

Article 120c covers indecent viewing, recording, or broadcasting, along with indecent exposure. This page looks only at cases where the accused pleaded guilty to charges that included it, so all 63 ended in a conviction.

92% of those convictions included confinement. The median confinement was 11 months. The median for all Navy and Marine Corps guilty pleas in those years was 6 months. A quarter of the sentences were 1.8 years or longer.

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

## More Long Terms Than Other Guilty Pleas

Confinement longer than one year was more common here: 24 of 63 convictions (38%), compared with 21% for all Navy and Marine Corps guilty pleas. Terms of more than 1 year but under 5 years were 25% of these convictions, compared with 16%. Terms of 5 years or more were 13%, compared with 5%.

Only 8% of these convictions had no confinement, compared with 15%. 27% included under 6 months, compared with 40%. Terms of 6 months to 1 year were 27% here, about the same as the 24% for all guilty pleas. Only a general court-martial can adjudge more than one year of confinement; a special court-martial is capped at one year.

| Adjudged confinement            | Convictions | Share here | Share, all Navy and Marine Corps guilty pleas in those years |
| ------------------------------- | ----------- | ---------- | ------------------------------------------------------------ |
| No confinement                  | 5           | 8%         | 15%                                                          |
| Under 6 months                  | 17          | 27%        | 40%                                                          |
| 6 months to 1 year              | 17          | 27%        | 24%                                                          |
| More than 1 year, under 5 years | 16          | 25%        | 16%                                                          |
| 5 years or more                 | 8           | 13%        | 5%                                                           |

## Sentences by Court Level

35 of the 63 cases (56%) were general courts-martial, the level that can impose long confinement and a dishonorable discharge. The other 28 were special courts-martial.

The median confinement was 1.5 years at general courts-martial. At special courts-martial, the median was 4 months, within their one-year cap.

## Discharges and Dismissals

Among 61 enlisted members convicted, 42 received a bad-conduct or dishonorable discharge (69%), more often than in all Navy and Marine Corps guilty pleas (60%). 13 of those discharges were dishonorable.

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.

## Other Charges in the Same Cases

44 of the 63 cases charged at least one other article. The most common were Article 134 (the general article) in 23 cases, Article 80 (attempt) in 13, Article 120 (sexual assault) in 11, Article 128 (assault) in 8, and Article 92 (orders violation) in 6.

The sentence covers every charge. Cases that charged Article 120c with sexual assault or other serious charges are part of the confinement figures above.

## Rank of the Accused

By rank, the accused were 43 junior enlisted members, 18 NCOs, and 2 officers. This group is more junior than all Navy and Marine Corps guilty pleas in those years.

All 63 pleaded guilty, so none of these cases was contested. Navy and Marine Corps records before December 2020 often omit the plea, so earlier cases appear here only when the record lists a guilty plea.

## Timing and Installations

The 63 cases were tried from January 2017 through December 2025\. The highest count was in 2021: 5 in 2017, 8 in 2018, 4 in 2019, 6 in 2020, 14 in 2021, 7 in 2022, 6 in 2023, 4 in 2024, and 9 in 2025.

Norfolk, Virginia (12), Camp Lejeune, North Carolina (7), Bremerton, Washington (7), San Diego, California (7), and Camp Pendleton, California (5) had the most cases. Together they account for 60% of the 63\. Larger installations try more cases of every kind, so these counts do not show a problem at any one base.

## A Covered Offense Under the New Rules

Article 120c is a covered offense. Since December 28, 2023, special trial counsel, not commanders, decide whether covered offenses are prosecuted. When every guilty finding is for an offense after December 27, 2023, the military judge sets the sentence within new sentencing parameters. Earlier, the Military Justice Act of 2016 took effect on January 1, 2019, and brought in written plea agreements. Offense dates are not in the records, so trials from 2024 on include both old-rule and new-rule cases.

## Limits of the Records

The records do not describe what was recorded or exposed, the evidence, or plea terms. They leave out cases handled by nonjudicial punishment or administrative separation.

For what the offense covers and how it is defended, see [Article 120c on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-120c/?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 tried 2017–2025: where the accused pleaded guilty to charges including Article 120c (indecent recording and exposure) (63 cases), compared with all Navy and Marine Corps guilty pleas 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 120c (Other Sexual Misconduct): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-120c-courts-martial/) (hub)
- [Sentences](https://www.bodiesburied.com/trends/sentences/) (hub)
- [Fewer or More? Indecent Recording And Exposure Charges at Navy-Marine Corps Courts-Martial, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-120c-trend-2017-2025/)
- [Article 120c Sentences in the Navy-Marine Corps: Confinement and Discharges, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-120c-sent-2017-2025/)
- [Not Guilty Pleas in Navy-Marine Corps Article 120c Cases: What Happened at Trial](https://www.bodiesburied.com/trends/navy-marine-corps-article-120c-acq-2017-2025/)
- [When Army Accused Plead Guilty to Indecent Recording And Exposure](https://www.bodiesburied.com/trends/army-article-120c-plea-2021-2025/) (another service)
- [Guilty Pleas in Air Force Indecent Recording And Exposure Cases: How Often, and What Came Next](https://www.bodiesburied.com/trends/air-force-article-120c-plea-2016-2025/) (another service)
- [Article 120c explained on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-120c/?ref=bodiesburied.com)
- [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.