Larceny at Navy-Marine Corps Courts-Martial, 2023: The Year in Numbers
In 2023, 31 Navy and Marine Corps courts-martial charged Article 121 (larceny), and 30 ended in a conviction on at least one charge. The median confinement was 5 months, slightly lower than the 6 months for all Navy and Marine Corps cases.
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Trends › By Offense › Article 121 › Navy-Marine Corps, 2023
Short answer: In 2023, 31 Navy and Marine Corps courts-martial charged Article 121 (larceny), and 30 ended in a conviction on at least one charge. The median confinement was 5 months, slightly lower than the 6 months for all Navy and Marine Corps cases. Only 2 of 30 convictions (7%) included more than one year, compared with 23% for all Navy and Marine Corps cases.
Most Sentences Were Short
80% of the 30 convictions included confinement. The median confinement was 5 months, and a quarter of terms were 8 months or more. For all Navy and Marine Corps cases in 2023, the median was 6 months.
These are adjudged sentences, set at trial before any plea-agreement cap, clemency, or appeal. Each one covers every charge in the case, not only the larceny charge.
In 2023, almost every case ended in a conviction, and most confinement terms were under a year. The records do not show the value of the property involved or other details that might separate one case from another.
Length of Confinement
The most common range was under 6 months: 13 convictions (43%), compared with 33% for all Navy and Marine Corps cases. Another 9 (30%) included 6 months to 1 year. 6 (20%) had no confinement, about the same as the 21% for all Navy and Marine Corps cases.
Only 2 convictions included more than one year, both between 1 and 5 years. For all Navy and Marine Corps cases, 23% of convictions did. Confinement of more than one year is available only at a general court-martial.
| Adjudged confinement | Convictions | Share here | Share, all Navy and Marine Corps cases in 2023 |
|---|---|---|---|
| No confinement | 6 | 20% | 21% |
| Under 6 months | 13 | 43% | 33% |
| 6 months to 1 year | 9 | 30% | 23% |
| More than 1 year, under 5 years | 2 | 7% | 19% |
| 5 years or more | 0 | 0% | 4% |
Special Courts-Martial Handled Most Cases
Of the 31 cases, 5 were general courts-martial (16%), compared with 46% for all Navy and Marine Corps cases in 2023. The rest were special courts-martial, which cap confinement at one year and cannot impose a dishonorable discharge. A general court-martial can impose any lawful sentence, including long confinement and a dishonorable discharge or dismissal.
The general court-martial share went from 35% in 2022 to 16% in 2023. The short sentences above were in the same year as that change. The records cannot show whether one caused the other.
Punitive Discharges Below the Service Rate
48% of enlisted convictions included a punitive discharge: 12 bad-conduct discharges and 2 dishonorable discharges. For all Navy and Marine Corps cases in 2023, the rate was 63%.
A sentence without a punitive discharge does not rule out an administrative separation later. These records cover courts-martial only, so any separation that followed would not appear here.
Pleas and Contested Trials
Of the 31 records, 30 list a plea: 23 guilty pleas and 7 contested cases, in which the accused pleaded not guilty to at least one charge. That makes 23% contested, lower than the 32% for all Navy and Marine Corps cases.
0 of 6 contested cases that reached a verdict ended in a full acquittal. In 2022, it was 1 of 6.
With only 6 contested cases that reached a verdict, a single verdict would change that count. It says little about how a contested larceny trial might end.
Rank of the Accused
The accused included 21 junior enlisted members (E-1 to E-4) and 9 NCOs (E-5 to E-9), with no officers or warrant officers. For all Navy and Marine Corps cases in 2023, 65% of the accused were junior enlisted, so this group was more junior.
The records do not break down sentences by rank, so they cannot show whether junior enlisted members and NCOs received different terms.
Charges Filed With Larceny
Article 121 was charged alone in 12 of the 31 cases. Article 92 (orders violation) was also charged in 6, Article 107 (false official statement) and Article 128 (assault) in 5 each, Article 87b (offenses against correctional custody) in 4, and Article 134 (general article) in 3.
Changes From 2022
There were 23 cases in 2022 and 31 in 2023. Median confinement went from 6 months to 5 months. Convictions with confinement went from 86% to 80%. Punitive discharges for enlisted members went from 45% to 48%, and the contested share went from 26% to 23%.
These are small groups, and a few cases can change any of the figures, so the comparison shows direction rather than exact change.
| 2022 | 2023 | |
|---|---|---|
| Cases | 23 | 31 |
| Contested (of pleas recorded) | 26% | 23% |
| Full acquittals (decided contested) | 1 of 6 | 0 of 6 |
| Convictions with confinement | 86% | 80% |
| Median confinement | 6 months | 5 months |
| Punitive discharge (enlisted) | 45% | 48% |
| General courts-martial | 35% | 16% |
Installations and Limits
Jacksonville, Florida and Camp Pendleton, California had 5 of these cases each, Parris Island, South Carolina had 3, and Camp Lejeune, North Carolina and Okinawa, Japan had 2 each. Together they account for 55% of the 31 cases. Larger installations try more cases of every kind.
The records give trial dates, not offense dates. They do not describe the evidence or plea terms. They omit larceny handled through nonjudicial punishment or administrative separation.
For what the offense covers and how it is defended, see Article 121 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 with a trial date in 2023 that charged Article 121 (31 cases), compared with all Navy and Marine Corps cases that year and with 2022.
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.
Related Analysis
- Article 121 (Larceny): Court-Martial Data and Trends (hub)
- By Year (hub)
- Navy-Marine Corps Article 121 Cases in 2022 (previous / next)
- How Navy-Marine Corps Larceny Cases Ended in 2024 (previous / next)
- How Has Article 121 Changed in Navy-Marine Corps Courts-Martial Since 2017? (the full trend)
- How Navy-Marine Corps Larceny Cases Ended in 2017
- How Navy-Marine Corps Larceny Cases Ended in 2020
- How Navy-Marine Corps Larceny Cases Ended in 2021
- Article 121 Sentences in the Navy-Marine Corps: Confinement and Discharges, 2017–2025
- Article 121 explained on the law firm's website
- Search every case in Military Trial Results (members)
Compare: federal court. Theft and Fraud by Dollar Loss: Federal Sentences vs. Article 121 Courts-Martial
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.