Fewer or More? Indecent Recording And Exposure Charges at Navy-Marine Corps Courts-Martial, 2017–2025

Trends › By Offense › Article 120c › Navy-Marine Corps

Based on 118 cases · 2017–2025 · Navy and Marine Corps records · data updated October 24, 2026

Sentences Were Longer Than the Service Median

Of the 118 cases, 113 ended in a conviction on at least one charge, and 103 of those sentences included confinement (91%). The median confinement was 11 months, compared with 6 months in the rest of the Navy and Marine Corps. A quarter of sentences were 2.5 years or longer.

Every length of confinement above six months was more common here than across the Navy and Marine Corps. Terms of 6 months to 1 year were 31% of convictions, compared with 22%. 43 of 113 convictions (38%) included confinement longer than one year, compared with 25%. Terms of 5 years or more were 13%, compared with 7%. Only 9% of convictions had no confinement.

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

Often Charged With Sexual Assault

Article 120c was the only charge in 27 of the 118 cases. In the rest it was charged with other offenses: Article 134 (the general article) in 40 cases, Article 120 (sexual assault) in 30, Article 80 (attempt) in 28, Article 128 (assault) in 25, and Article 92 (orders violation) in 13.

Where sexual assault or attempt charges were part of the case, the sentence covers them too. The records do not divide a sentence among its charges.

Discharges and Dismissals

78% of enlisted convictions included a punitive discharge: 52 bad-conduct discharges and 31 dishonorable discharges. That is higher than the 62% for all Navy and Marine Corps convictions. All 4 convicted officers or warrant officers were dismissed. A sentence without a punitive discharge does not rule out a later administrative separation.

General Courts-Martial Handled Most Cases

70 of the 118 cases (59%) were general courts-martial, compared with 43% in the rest of the Navy and Marine Corps. A general court-martial can impose long confinement and a dishonorable discharge. The other 48 were special courts-martial, which are limited to one year of confinement and no dishonorable discharge.

The median confinement was 2 years at the general level and 5 months at the special level. 33% of general court-martial cases were contested, compared with 26% of special court-martial cases.

Guilty Pleas and Contested Trials

Of the 90 records that list a plea, 63 were guilty pleas and 27 were contested, meaning a not-guilty plea to at least one charge. That makes 30% contested, about the same as the 32% in the rest of the Navy and Marine Corps. Before December 2020 the records often omit the plea, so only records that include it are counted.

Of the 27 contested cases that reached a verdict, 5 ended in a full acquittal (19%), lower than the 31% in the rest of the Navy and Marine Corps. Another 7 (26%) ended in a partial acquittal: not guilty of at least one charge or specification and guilty of another.

Cases by Year

Yearly counts were 16 in 2017, 18 in 2018, 13 in 2019, 15 in 2020, and 20 in 2021, then 11 in 2022, 7 in 2023, 6 in 2024, and 12 in 2025. The 118 cases are 3% of the 3,740 Navy and Marine Corps courts-martial over those years.

Convictions including Article 120c were highest in 2021, at 19, which was 5% of convictions with offenses listed. There were 5 in 2024 and 10 in 2025. In 2017–2019, Article 120c was part of 47 of 1,243 convictions (4%). In 2023–2025, it was part of 22 of 940 (2%).

Rank and Location

The accused were 67 junior enlisted members (E-1 to E-4), 45 NCOs (E-5 to E-9), and 4 officers or warrant officers. For all Navy and Marine Corps cases, 63% of the accused were junior enlisted, so this group is more senior.

Camp Lejeune, North Carolina, had 20 cases; Norfolk, Virginia, 15; Bremerton, Washington, 14; Camp Pendleton, California, 12; and San Diego, California, 9. Together they account for 59% of the 118 cases. Larger installations try more cases of every kind, so these totals do not by themselves show a local problem.

Rule Changes and Unknowns

The Military Justice Act of 2016 took effect on January 1, 2019. It added written plea agreements, fixed panel sizes, and judge-alone special courts-martial capped at six months. Article 120c is a covered offense. Since December 28, 2023, special trial counsel decide whether to prosecute it. For offenses after December 27, 2023, the military judge sentences within new parameters. The records give trial dates, not offense dates, so they cannot show which rules applied to a given case.

The evidence, the plea terms, and conduct handled outside a court-martial do not appear in these records.

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.