Navy-Marine Corps Courts-Martial With Article 121 and Article 81, 2021–2025

Trends › By Offense › Article 121 › Navy-Marine Corps, with Article 81

Based on 16 cases · 2021–2025 · Navy and Marine Corps records · data updated October 24, 2026

Punitive Discharges After Conviction

Of the 16 convicted enlisted members, 13 received a punitive discharge: 12 bad-conduct discharges and 1 dishonorable discharge. In Navy and Marine Corps Article 121 cases overall, the share was 52%.

A punitive discharge is a bad-conduct discharge or a dishonorable discharge for an enlisted member. A sentence without one does not rule out a later administrative separation.

How Long Was the Confinement?

All 16 cases ended in a conviction, and all 16 sentences included confinement. The median was 9 months. Across all Navy and Marine Corps Article 121 cases, the median was 5 months.

A quarter of the confinement terms were 1.5 years or longer. Each figure is the adjudged sentence, meaning the sentence set at trial before any plea-agreement cap, clemency, or appeal. It covers every charge in the case.

Few Contested Cases

In 14 of the 16 cases, the accused pleaded guilty. The other 2 were contested, meaning the accused pleaded not guilty to at least one charge. The contested share was 12%, compared with 24% in all Navy and Marine Corps Article 121 cases in 2021–2025.

Almost All Junior Enlisted

Junior enlisted members (E-1 to E-4) were 94% of the accused. NCOs were 6%, and no officers were charged. In all Navy and Marine Corps Article 121 cases, junior enlisted members were 57%.

General and Special Courts-Martial

The cases were split evenly: 8 of 16 (50%) were general courts-martial, and the rest were special courts-martial. A general court-martial can impose long confinement and a dishonorable discharge. A special court-martial caps confinement at one year and can impose a bad-conduct discharge but not a dishonorable discharge.

Charges Beyond Larceny and Conspiracy

Every case charged at least one article besides Article 121. After Article 81, the most common were Article 80 (attempt) in 4 cases, Article 87a (resisting apprehension) in 3, Article 87b (offenses against correctional custody) in 3, and Article 134 (general article) in 3.

When the Cases Were Tried

Trials ran from February 2021 to June 2025. By year, there were 4 cases in 2021, 2 in 2022, 3 in 2023, 4 in 2024, and 3 in 2025.

Rule Changes and Gaps in the Records

Court-martial rules changed during these years. Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute covered offenses such as sexual assault, domestic violence, and murder. For a case in which every guilty finding is for an offense after December 27, 2023, the military judge sets the sentence within new sentencing parameters.

Both rules depend on when the offense happened. The records give only the trial date, so the 2024 and 2025 trials may include cases under either set of rules. The records also leave out the evidence, the plea terms, and any matter resolved by nonjudicial punishment, administrative separation, or no action.

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.

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.