Article 121 Cases at San Diego, California, 2013–2018: 38 Courts-Martial

Trends › By Installation › San Diego, California › Article 121, 2013–2018

Based on 38 cases · 2013–2018 · Navy and Marine Corps records · data updated October 24, 2026

Almost Every Larceny Case Was a Guilty Plea

Of the 38 accused in theft cases at San Diego in these years, 35 pleaded guilty. Only 3 contested at least one charge with a not-guilty or mixed plea. The contested share of 8% compares with 10% across the Navy and Marine Corps as a whole.

All 38 cases ended in a conviction on at least one charge. The records do not include plea terms, so they cannot show what, if anything, the accused received in exchange for a guilty plea.

NCOs Were the Largest Group

Of the accused, 21 were NCOs (E-5 to E-9), 16 were junior enlisted members (E-1 to E-4), and 1 was an officer or warrant officer. In Navy and Marine Corps-wide Article 121 cases, junior enlisted members were 55% of the accused. The group at San Diego was more senior.

The records do not describe what was taken, its value, or who owned it. They also do not show whether a case involved government property or another service member's property.

Most Confinement Was Between 6 Months and 1 Year

Confinement was part of 36 of the 38 sentences. The median confinement was 6 months, the same as the 6 months for Navy and Marine Corps-wide Article 121 cases. A quarter of confinement sentences were 1 year or longer.

The most common sentence length was 6 months to 1 year: 17 convictions (45%), compared with 37% elsewhere. Confinement under 6 months was 15 convictions (39%). Sentences longer than one year were 4 of 38 (11%), compared with 14% in the rest of the Navy and Marine Corps. Only 2 convictions (5%) had no confinement. All are adjudged sentences, before any plea-agreement cap, clemency, or appeal.

Nearly All Punitive Discharges Were Bad-Conduct Discharges

Of 37 convicted enlisted members, 25 received a punitive discharge: 24 bad-conduct discharges and 1 dishonorable discharge. Across all Navy and Marine Corps Article 121 cases in 2013–2018, the punitive discharge rate was 68%.

The 1 convicted officer or warrant officer was not dismissed. With or without a punitive discharge, an administrative separation can still follow. These records do not include administrative separations.

Few General Courts-Martial

Only 7 of the 38 cases were general courts-martial (18%), compared with 24% in all Navy and Marine Corps Article 121 cases in 2013–2018. Special courts-martial tried the rest.

Court level sets the maximum sentence. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge. A general court-martial can impose any lawful sentence. Only a general court-martial can impose more than one year of confinement.

Other Charges in Larceny Cases

Article 121 was the only charge in 9 of the 38 cases. Service-wide, 66 of 249 Navy and Marine Corps larceny cases charged it alone. Article 107 (false official statement) was the most common other charge, in 10 cases. Article 80 (attempt), Article 92 (orders violation), and Article 81 (conspiracy) were charged in 7 each, and Article 112a (drug) in 5.

A sentence covers the whole case. The sentence figures above include those other charges as well as the theft. The records do not divide a sentence among charges, so they cannot show how much of a sentence was for the theft.

Cases by Year

The trials run from January 2013 to August 2018. Most were in the first 3 years: 11 in 2013, 5 in 2014, and 12 in 2015. There were 7 in 2016, 1 in 2017, and 2 in 2018. Larceny cases were 13% of the 285 courts-martial at San Diego, California over the period.

Every trial here came before January 1, 2019, when the Military Justice Act of 2016 took effect. That law set fixed panel sizes, created judge-alone special courts-martial capped at six months with no punitive discharge, and introduced written plea agreements. None of those changes applied to these cases.

What the Records Cannot Show

The records give trial dates, not offense dates. They do not show the evidence, the plea terms, or thefts handled through nonjudicial punishment or administrative separation. Navy and Marine Corps records before December 2020 often omit the forum, so these records do not show who decided guilt.

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.