How San Diego, California Handled Larceny Cases (Article 121), 2019–2022

Trends › By Installation › San Diego, California › Article 121, 2019–2022

Based on 23 cases · 2019–2022 · Navy and Marine Corps records · data updated October 24, 2026

Many Convictions Had No Confinement

All 23 larceny cases at San Diego in these years ended in a conviction. Confinement was part of 61% of them. The other 9 convictions (39%) had no confinement, compared with 20% across all Navy and Marine Corps Article 121 cases in 2019–2022.

These are adjudged sentences, announced at trial before any plea-agreement cap, clemency, or appeal. The records do not explain why some sentences included confinement and others did not. The sentences here covered a wide range, from no confinement to more than one year.

Median Confinement Was Longer When Imposed

Among sentences that included confinement, the median was 9 months. In the rest of the Navy and Marine Corps, the median was 7 months. A quarter of confinement sentences here were 1 year or longer.

Confinement under 6 months was less common here: 4 convictions (17%), compared with 30% elsewhere. Confinement of 6 months to 1 year was 7 convictions (30%), compared with 33%. Sentences longer than one year were 3 of 23 convictions (13%), compared with 17% in Navy and Marine Corps Article 121 cases overall. No sentence was 5 years or longer.

Punitive Discharges Were Less Common Than the Service Rate

Of 23 convicted enlisted members, 12 received a punitive discharge: 10 bad-conduct discharges and 2 dishonorable discharges. Across all Navy and Marine Corps Article 121 cases in 2019–2022, the rate was 63%.

Only a general court-martial can impose a dishonorable discharge. A member without a punitive discharge can still face an administrative separation. Administrative separations are not part of these court records, so they cannot show how many convicted members left the service.

Pleas Were About the Same as the Service

Of the 23 accused, 18 pleaded guilty and 5 contested at least one charge with a not-guilty or mixed plea. The contested share of 22% was about the same as the 21% in Navy and Marine Corps-wide Article 121 cases.

The records do not include plea terms. The Military Justice Act of 2016 took effect on January 1, 2019 and introduced written plea agreements. This data shows only the result, not what an agreement said about confinement or discharge. Cases with offenses before 2019 stayed under the old rules. The records give trial dates, not offense dates, so some of these trials may have been under the older rules.

Court Level and Rank

Special courts-martial tried 17 of the cases and general courts-martial tried 6. The general share of 26% was lower than the 32% across the Navy and Marine Corps as a whole. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge. Since 2019, a special court-martial can also be tried by a military judge alone, with confinement capped at six months and no punitive discharge.

By rank, the accused were 12 NCOs and 11 junior enlisted members. There were 0 officers. That group was more senior than in Navy and Marine Corps-wide Article 121 cases.

Credit Cards, Drugs, and Absences

Larceny was the only charge in 6 of the 23 cases. No other charge was more common than the rest. Article 112a (drug), Article 107 (false official statement), Article 121a (fraudulent use of credit cards, debit cards), Article 86 (AWOL), and Article 80 (attempt) were each charged in 4 cases.

Each sentence covers every charge in its case. The sentences above often combined theft with another offense.

Cases by Year

The trials run from January 2019 to November 2022. There were 8 in 2019, 6 in 2020, 5 in 2021, and 4 in 2022. Over the period, larceny cases were 16% of the 142 courts-martial at San Diego, California.

There were only 23 cases. Every percentage here is based on a small number, and a few sentences can change it.

What the Records Cannot Show

Trial records cover only cases that reached a courtroom. Thefts handled through nonjudicial punishment, administrative separation, or no action are not included. The records do not describe the evidence, the property, or the plea terms. 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.