Navy-Marine Corps Cases Charging Both Article 134 and Article 80

Trends › By Offense › Article 134 › Navy-Marine Corps, with Article 80

Based on 47 cases · 2021–2026 · Navy and Marine Corps records · data updated October 24, 2026

Almost All Were General Courts-Martial

Of the 47 cases, 43 were tried at a general court-martial (91%). Special courts-martial made up the rest. A general court-martial can impose any lawful sentence, including long confinement and a dishonorable discharge or dismissal.

A special court-martial caps confinement at one year and cannot impose a dishonorable discharge. Only a general court-martial can adjudge a term longer than one year, so the court level matters for the sentence figures below.

Confinement Terms of 5 Years or More

Terms of 5 years or more made up 26% of convictions in these cases. For all Navy and Marine Corps Article 134 cases in 2021–2026, that band made up 12%. Terms longer than one year came in 26 of 46 convictions (57%), compared with 47%.

Shorter terms were less common. Terms under 6 months made up 7% of convictions, compared with 21%. Terms of 6 months to 1 year made up 24%, compared with 17%. No confinement was adjudged in 6 convictions (13%), compared with 15%.

Median and Upper Quarter

Confinement was part of 87% of the 46 convictions. Half of those terms were 2 years or less, and a quarter were 6 years or longer. The median for all Navy and Marine Corps Article 134 cases was 1.5 years.

These are adjudged sentences, the terms announced at trial. They come before any plea-agreement cap, clemency, or appeal. Each one covers all charges in the case.

Discharges and Dismissals

A punitive discharge followed 77% of enlisted convictions: 9 bad-conduct discharges and 24 dishonorable discharges. Across all Navy and Marine Corps Article 134 cases, the rate was 73%.

The group includes 2 convicted officers or warrant officers, and 2 were dismissed. A dismissal is the officer equivalent of a punitive discharge. A sentence with no punitive discharge does not rule out a later administrative separation.

Charges That Appeared With the Pair

Besides Article 80, the most common other charge was Article 120b (child sexual abuse), in 13 cases. Article 82 (solicitation) appeared in 8 cases. Article 81 (conspiracy) and Article 120c (indecent recording and exposure) appeared in 3 each.

A case is counted under every article it charged. The sentence in each case covers all of those charges together. The records list the charges but do not describe the conduct behind them.

Pleas and Acquittals

There were 34 guilty pleas and 13 contested cases. A contested case is one where the accused pleaded not guilty to at least one charge. The contested share was 28%, about the same as the 29% for Navy and Marine Corps Article 134 cases overall.

Of the 13 contested cases that reached a verdict, 8% ended in a full acquittal, close to the 9% for all Navy and Marine Corps Article 134 cases. Another 3 ended in a partial acquittal: not guilty of at least one charge or specification and guilty of another.

Rank, Years, and Installations

Among the accused with rank recorded, 28 were junior enlisted members, 16 were NCOs, and 2 were officers. The group was more senior than Navy and Marine Corps Article 134 cases as a whole.

The cases were tried from January 2021 through July 2026. There were 19 in 2021, 5 in 2022, 4 in 2023, 6 in 2024, 5 in 2025, and 8 in 2026, a partial year.

Mayport, Florida tried 6 cases and Bremerton, Washington tried 5. Marine Corps Base Hawaii, Kaneohe Bay, San Diego, California, and Jacksonville, Florida tried 4 each. These five installations account for 49% of the 47 cases. Larger installations try more cases overall, so a high count alone does not show a problem at any base.

Limits of These Records

Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute covered offenses such as sexual assault, domestic violence, and murder. For offenses after December 27, 2023, when every guilty finding is for such an offense, the military judge sets the sentence within new sentencing parameters.

Both rules depend on the offense date, and the records give only the trial date. Cases tried from 2024 on therefore mix old-rule and new-rule cases. The records also do not describe the evidence or the plea terms, and they leave out nonjudicial punishment and administrative separation.

For what the offense covers and how it is defended, see Article 134 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.