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# Guilty Pleas in Navy-Marine Corps Larceny Cases: How Often, and What Came Next
- URL: https://www.bodiesburied.com/trends/navy-marine-corps-article-121-plea-2017-2025/
- Published: 2026-10-28T08:05:55.000Z
- Updated: 2026-11-03T01:47:01.000Z
- Description: Navy and Marine Corps records contain 172 guilty-plea courts-martial from 2017–2025 that included Article 121 (larceny). 54% of enlisted convictions included a punitive discharge, lower than the 60% for all Navy and Marine Corps guilty pleas.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Article 121, Navy-Marine Corps

[Trends](https://www.bodiesburied.com/trends/) › [By Offense](https://www.bodiesburied.com/trends/by-offense/) › [Article 121](https://www.bodiesburied.com/trends/article-121-courts-martial/) › Guilty Pleas in Navy-Marine Corps Larcen

**Short answer:** Navy and Marine Corps records contain 172 guilty-plea courts-martial from 2017–2025 that included Article 121 (larceny). 54% of enlisted convictions included a punitive discharge, lower than the 60% for all Navy and Marine Corps guilty pleas. The median confinement was 6 months, the same as for all Navy and Marine Corps guilty pleas.

Based on 172 cases · 2017–2025 · Navy and Marine Corps records · data updated October 24, 2026

## Most Cases Were Special Courts-Martial

130 of the 172 cases were special courts-martial, and only 42 were general courts-martial. The general court-martial share was 24%, compared with 37% for all Navy and Marine Corps guilty pleas in those years.

Sentence length differed by court level. The median confinement was 1 year at general courts-martial and 4 months at special courts-martial. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge.

## Median Confinement Matched the Wider Group

Of 172 convictions, 134 included confinement. The median confinement was 6 months, the same as for all Navy and Marine Corps guilty pleas. A quarter of sentences were 11 months or longer.

These are adjudged sentences, set at trial before any plea-agreement cap, clemency, or appeal. They cover every charge in the case. A larceny case that also included drug or false-statement charges has a single sentence for all of them.

## Fewer Long Sentences, More With None

Only 14 of 172 convictions (8%) included more than one year of confinement, compared with 21% for all Navy and Marine Corps guilty pleas. Terms above 1 year and under 5 years were 6% here, compared with 16%. Terms of 5 years or more were 2%, compared with 5%.

38 convictions (22%) had no confinement, compared with 15%. Terms from 6 months to 1 year were more common: 33% compared with 24%. Terms under 6 months were 37%, about the same as the 40% for all guilty pleas.

| Adjudged confinement            | Convictions | Share here | Share, all Navy and Marine Corps guilty pleas in those years |
| ------------------------------- | ----------- | ---------- | ------------------------------------------------------------ |
| No confinement                  | 38          | 22%        | 15%                                                          |
| Under 6 months                  | 63          | 37%        | 40%                                                          |
| 6 months to 1 year              | 57          | 33%        | 24%                                                          |
| More than 1 year, under 5 years | 11          | 6%         | 16%                                                          |
| 5 years or more                 | 3           | 2%         | 5%                                                           |

## Punitive Discharges

54% of enlisted convictions included a punitive discharge: 78 bad-conduct discharges and 11 dishonorable discharges. For all Navy and Marine Corps guilty pleas in those years, the rate was 60%.

The records list 5 convicted officers or warrant officers, and 0 were dismissed. A sentence without a punitive discharge does not rule out a later administrative separation, which falls outside these records.

## Charges Filed With Larceny

In 114 of the 172 cases, at least one other article was charged. Article 107 (false official statement) was the most common other charge, in 27 cases. Article 81 (conspiracy) and Article 112a (drugs) each appeared in 19, Article 92 (orders violation) in 17, and Article 80 (attempt) in 16.

The records list these charges but not the value of property taken or whether restitution was made. A conspiracy charge requires an agreement with at least one other person. The 19 conspiracy cases each charged more than one participant.

## Rank of the Accused

Among the accused with rank recorded, 94 were junior enlisted, 72 were NCOs, and 5 were officers. This group is more senior than all Navy and Marine Corps guilty pleas in those years. Rank here is the grade recorded at trial. The records do not give time in service.

## Year-by-Year and Location

The trials took place from January 2017 to November 2025\. The yearly count was lowest in 2017, at 11, and highest in 2021, at 26, with 20 in 2018, 19 in 2019, 12 in 2020, 17 in 2022, 23 in 2023, 24 in 2024, and 20 in 2025.

San Diego, California had the most cases, 27, followed by Camp Pendleton, California (21), Camp Lejeune, North Carolina and Norfolk, Virginia (19 each), and Jacksonville, Florida (12). Together they account for 57% of the 172\. Larger installations try more cases of every kind, so a count alone does not show anything about a base.

## Rule Changes Across the Period

The Military Justice Act of 2016 took effect on January 1, 2019\. It brought written plea agreements, fixed panel sizes, and judge-alone special courts-martial capped at six months with no punitive discharge. Offenses from before 2019 kept the old rules.

Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute covered offenses such as sexual assault, domestic violence, and murder. When every guilty finding is for an offense after December 27, 2023, the military judge sets the sentence within new sentencing parameters. The records give trial dates, not offense dates, so cases near each change include both old and new rules. The data cannot show whether either change affected sentences.

## What the Records Do Not Show

Trial records omit the evidence and the plea terms. Thefts handled through nonjudicial punishment, administrative separation, or no action are not part of this count.

For what the offense covers and how it is defended, see [Article 121 on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-121/?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 121 (larceny) (172 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 121 (Larceny): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-121-courts-martial/) (hub)
- [Sentences](https://www.bodiesburied.com/trends/sentences/) (hub)
- [How Has Article 121 Changed in Navy-Marine Corps Courts-Martial Since 2017?](https://www.bodiesburied.com/trends/navy-marine-corps-article-121-trend-2017-2025/)
- [Article 121 Sentences in the Navy-Marine Corps: Confinement and Discharges, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-121-sent-2017-2025/)
- [Not Guilty Pleas in Navy-Marine Corps Article 121 Cases: What Happened at Trial](https://www.bodiesburied.com/trends/navy-marine-corps-article-121-acq-2017-2025/)
- [Guilty Pleas in Army Larceny Cases: How Often, and What Came Next](https://www.bodiesburied.com/trends/army-article-121-plea-2021-2025/) (another service)
- [Pleading Guilty to Article 121 in the Air Force: What Sentences Followed?](https://www.bodiesburied.com/trends/air-force-article-121-plea-2016-2025/) (another service)
- [Article 121 explained on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-121/?ref=bodiesburied.com)
- [Search every case in Military Trial Results](https://www.bodiesburied.com/military-trial-results/) (members)

**Compare: federal court.** [Theft and Fraud by Dollar Loss: Federal Sentences vs. Article 121 Courts-Martial](https://www.bodiesburied.com/trends/federal-theft-fraud-dollar-loss-vs-article-121/)

**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.