NewKnow Your Judge: the court-martial record of 294 military judges → NewLearn Your Lawyer: the court-martial record of 335 military lawyers →
Where All The Bodies Are Buried
Understanding Trends

Navy-Marine Corps Article 121 Cases in 2025

In 2025, 27 Navy and Marine Corps courts-martial charged Article 121 (larceny), and 26 ended in a conviction on at least one charge. The median confinement was 4 months, the same as for all Navy and Marine Corps cases.

Understanding Trends in Military Practice · 6 min read

Trends › By Offense › Article 121 › Navy-Marine Corps, 2025

Short answer: In 2025, 27 Navy and Marine Corps courts-martial charged Article 121 (larceny), and 26 ended in a conviction on at least one charge. The median confinement was 4 months, the same as for all Navy and Marine Corps cases. 57% of convicted enlisted members received a punitive discharge, compared with 46% for all Navy and Marine Corps cases.

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

NCOs Outnumbered Junior Enlisted Members

NCOs made up 50% of the accused, junior enlisted members (E-1 to E-4) 42%, and officers 8%. For all Navy and Marine Corps cases in 2025, junior enlisted members were 62% of the accused.

The records do not break down sentences by rank for this group, so they cannot show whether NCOs and junior enlisted members received different outcomes.

Every Punitive Discharge Was a Bad-Conduct Discharge

Of 23 convicted enlisted members, 13 received a punitive discharge, and all 13 were bad-conduct discharges. The 57% rate was higher than the 46% for all Navy and Marine Corps cases in 2025.

A bad-conduct discharge is the punitive discharge a special court-martial can impose; a dishonorable discharge requires a general court-martial. The records list 2 convicted officers or warrant officers, and neither was dismissed. A sentence without a punitive discharge does not rule out a later administrative separation.

Confinement Was Usually a Few Months

69% of the 26 convictions included confinement. The median confinement was 4 months, the same as the 4-month median for all Navy and Marine Corps cases. A quarter of terms were 9 months or more.

These are adjudged sentences, set at trial before any plea-agreement cap, clemency, or appeal. A sentence covers all the charges in a case.

In 2025, most larceny convictions included short confinement or none. The records do not show the amount taken or any other detail of the conduct.

Length of Confinement

8 convictions (31%) had no confinement, the same as the 31% for all Navy and Marine Corps cases. 10 (38%) included under 6 months, about the same as the 37%. 6 convictions (23%) included 6 months to 1 year, higher than the 16% for all Navy and Marine Corps cases.

Only 2 of 26 convictions (8%) included more than one year, both between 1 and 5 years, compared with 16% for all Navy and Marine Corps cases. More than a year of confinement can be adjudged only at a general court-martial.

Adjudged confinementConvictionsShare hereShare, all Navy and Marine Corps cases in 2025
No confinement831%31%
Under 6 months1038%37%
6 months to 1 year623%16%
More than 1 year, under 5 years28%11%
5 years or more00%5%

Court Level

Of the 27 cases, 5 were general courts-martial (19%), compared with 36% for all Navy and Marine Corps cases. 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.

With few general courts-martial, few convictions included more than one year of confinement. No convicted enlisted member here received a dishonorable discharge.

Few Contested Cases

Plea records cover 25 of the 27 cases: 20 guilty pleas and 5 not-guilty or mixed pleas. That makes 20% contested. For all Navy and Marine Corps cases in 2025, 37% were contested. A contested case is one where the accused pleads not guilty to at least one charge.

0 of 5 contested cases that reached a verdict ended in a full acquittal. In 2024 the count was 0 of 6. These are very small numbers, and a single verdict would change them.

Other Charges in These Cases

Article 121 was the only charge in 8 of 27 cases. Other cases also charged Article 92 (orders violation) and Article 107 (false official statement) in 5 each, Article 108 (military property) in 4, and Article 121a (fraudulent use of credit cards, debit cards) and Article 81 (conspiracy) in 3 each.

Changes From 2024

There were 30 cases in 2024 and 27 in 2025. Median confinement went from 3 months to 4 months. Convictions with confinement went from 63% to 69%. Punitive discharges for enlisted members went from 44% to 57%. The contested share was 20% in both years, and the general court-martial share went from 20% to 19%.

In groups this small, a few cases can change the figures. The changes show direction, not exact size.

20242025
Cases3027
Contested (of pleas recorded)20%20%
Full acquittals (decided contested)0 of 60 of 5
Convictions with confinement63%69%
Median confinement3 months4 months
Punitive discharge (enlisted)44%57%
General courts-martial20%19%

Installations, Rules, and Limits

Camp Lejeune, North Carolina and Bremerton, Washington had 5 of these cases each. MCAS Cherry Point, North Carolina, Camp Pendleton, California, and San Diego, California had 3 each. Together they account for 70% of the 27 cases. Larger installations try more cases of every kind.

When every guilty finding in a case is for an offense after December 27, 2023, the military judge sets the sentence within new sentencing parameters. That rule depends on the offense date, which these records do not give. They also do not describe the evidence, plea terms, or 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 2025 that charged Article 121 (27 cases), compared with all Navy and Marine Corps cases that year and with 2024.

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.

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.

↑ Top