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# Larceny Cases at San Diego, California: 2013–2018 vs. 2019–2022
- URL: https://www.bodiesburied.com/trends/san-diego-california-article-121-before-after-2019/
- Published: 2026-10-28T06:49:57.000Z
- Updated: 2026-11-03T01:47:49.000Z
- Description: San Diego, California had about 6 larceny cases under Article 121 a year in both 2013–2018 and 2019–2022, but sentences changed. Convictions with confinement went from 95% to 61%.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, San Diego, California, Article 121, Navy-Marine Corps

[Trends](https://www.bodiesburied.com/trends/) › [By Installation](https://www.bodiesburied.com/trends/by-installation/) › [San Diego, California](https://www.bodiesburied.com/trends/courts-martial-at-san-diego-california/) › Article 121

**Short answer:** San Diego, California had about 6 larceny cases under Article 121 a year in both 2013–2018 and 2019–2022, but sentences changed. Convictions with confinement went from 95% to 61%. Punitive discharges for convicted enlisted members went from 68% to 52%, lower than the 63% across the Navy and Marine Corps. When confinement was imposed, the median went from 6 months to 9 months.

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

## Fewer Sentences Included Confinement

In 2013–2018, 95% of larceny convictions at San Diego included confinement. Of the 23 convictions from 2019 through 2022, 61% did. 9 of those convictions (39%) had no confinement, compared with 20% in Navy and Marine Corps Article 121 cases in the same years.

When confinement was imposed, it was longer than before. The median confinement went from 6 months to 9 months. The service-wide median was 7 months. A quarter of the confinement sentences were 1 year or longer.

## Both Periods Side by Side

The table below compares the 2 periods. The earlier period had 38 cases across 6 years with cases on record. The later period had 23\. Both periods had about 6 cases a year in full years.

Other measures also changed. The contested share went from 8% to 22%. General courts-martial went from 18% to 26% of cases. These groups are small, and a few cases can change a percentage a great deal. The changes show direction, not exact size.

|                                     | 2013–2018 | 2019–2022 |
| ----------------------------------- | --------- | --------- |
| Cases                               | 38        | 23        |
| Contested (of pleas recorded)       | 8%        | 22%       |
| Full acquittals (decided contested) | 0 of 3    | 0 of 5    |
| Convictions with confinement        | 95%       | 61%       |
| Median confinement                  | 6 months  | 9 months  |
| Punitive discharge (enlisted)       | 68%       | 52%       |
| General courts-martial              | 18%       | 26%       |

## Punitive Discharges at San Diego and Service-Wide

A punitive discharge is a bad-conduct or dishonorable discharge. Of 23 convicted enlisted members here, 12 received one (52%). Of those 12, 2 were dishonorable discharges. In Navy and Marine Corps Article 121 cases overall, the rate was 63%.

A sentence without a punitive discharge does not mean the member stayed in the service. An administrative separation can still follow, and these records do not include administrative separations.

## Sentence Lengths Compared With the Service

The second table shows sentence lengths. Confinement under 6 months was less common here: 17%, compared with 30% service-wide. Confinement of 6 months to 1 year was about the same: 30%, compared with 33%.

Of 23 convictions, 3 carried more than one year of confinement (13%), compared with 17% in the Navy and Marine Corps as a whole. No sentence was 5 years or longer. Only a general court-martial can impose more than one year of confinement. These are adjudged sentences, before any plea-agreement cap, clemency, or appeal, and each covers every charge in the case.

| Adjudged confinement            | Convictions | Share here | Share, all Navy and Marine Corps Article 121 cases in 2019–2022 |
| ------------------------------- | ----------- | ---------- | --------------------------------------------------------------- |
| No confinement                  | 9           | 39%        | 20%                                                             |
| Under 6 months                  | 4           | 17%        | 30%                                                             |
| 6 months to 1 year              | 7           | 30%        | 33%                                                             |
| More than 1 year, under 5 years | 3           | 13%        | 15%                                                             |
| 5 years or more                 | 0           | 0%         | 1%                                                              |

## Pleas and Verdicts

A case is contested when the accused pleads not guilty to at least one charge. San Diego had 5 contested cases and 18 guilty pleas. The contested share was 22%, about the same as the 21% service-wide.

None of the 5 contested cases ended in a full acquittal. All 23 cases ended in a conviction on at least one charge. In 2013–2018, 0 of 3 contested cases that reached a verdict ended in a full acquittal.

## Cases by Year, 2019 to 2022

The records run from January 2019 to November 2022\. The count was lower each year: 8 in 2019, 6 in 2020, 5 in 2021, and 4 in 2022\. Larceny charges were in 16% of the 142 courts-martial at San Diego in those years.

The records give trial dates, not offense dates. They cannot show when the conduct in any case took place, or which cases involved offenses from before 2019.

## Rank and Court Level

NCOs (E-5 to E-9) were 52% of the accused, and junior enlisted members (E-1 to E-4) were 48%. There were 0 officers. Service-wide, junior enlisted members were 55% of Article 121 accused.

Most cases were special courts-martial, which cap confinement at one year and cannot impose a dishonorable discharge. General courts-martial tried 6 of the 23 cases (26%).

## Other Charges in the Same Cases

Larceny was the only charge in 6 of the 23 cases, compared with 41 of 140 Navy and Marine Corps Article 121 cases. 5 other articles were each charged in 4 cases: Article 112a (drug), Article 107 (false official statement), Article 121a (fraudulent use of credit cards, debit cards), Article 86 (AWOL), and Article 80 (attempt). A sentence covers every charge, so these other charges are part of the confinement and discharge figures.

## What the Records Cannot Show

Only courts-martial are counted. Thefts resolved through nonjudicial punishment, administrative separation, or no action are not in this data. The records do not show the evidence or any plea terms. Navy and Marine Corps records before December 2020 often omit the plea, so the plea figures use only the records that list one.

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

Courts-martial tried at San Diego, California that charged Article 121 (found guilty, not guilty, or both): 2013–2018 (38) and 2019–2022 (23). Comparisons use every Navy and Marine Corps case charging Article 121 in 2019–2022.

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

- [San Diego, California: Court-Martial Data and Trends](https://www.bodiesburied.com/trends/courts-martial-at-san-diego-california/) (hub)
- [Article 121 (Larceny): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-121-courts-martial/) (hub)
- [By Installation](https://www.bodiesburied.com/trends/by-installation/) (hub)
- [San Diego, California Courts-Martial, 2013–2018: What 285 Cases Show](https://www.bodiesburied.com/trends/san-diego-california-courts-martial-2013-2018/) (the whole docket)
- [Inside 173 Courts-Martial at San Diego, California, 2019–2023](https://www.bodiesburied.com/trends/san-diego-california-courts-martial-2019-2023/) (the whole docket)
- [San Diego, California Courts-Martial, 2024–2026: What 126 Cases Show](https://www.bodiesburied.com/trends/san-diego-california-courts-martial-2024-2026/) (the whole docket)
- [Did Larceny Cases at Camp Lejeune, North Carolina Change After 2019?](https://www.bodiesburied.com/trends/camp-lejeune-north-carolina-article-121-before-after-2019/) (same offense, another installation)
- [Larceny Cases at Camp Pendleton, California: 2017–2018 vs. 2019–2023](https://www.bodiesburied.com/trends/camp-pendleton-california-article-121-before-after-2019/) (same offense, another installation)
- [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 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)

## Military Judges Who Presided Over Article 121 Cases at San Diego, California, 2019–2022

- [Andrea Lockhart](https://www.bodiesburied.com/judge-andrea-lockhart/)
- [Ryan Stormer](https://www.bodiesburied.com/judge-ryan-stormer/)

Names and links only. Each judge's record of pleas, findings, and sentences is on their Know Your Judge page, part of the [Court-Martial Characters](https://www.bodiesburied.com/judges/) membership.

**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.