How San Diego, California Handled General Article Cases (Article 134), 2013–2018

Trends › By Installation › San Diego, California › Article 134, 2013–2018

Based on 28 cases · 2013–2018 · Navy and Marine Corps records · data updated October 24, 2026

Median Confinement Was Longer Than the Service

Of 25 convictions, 24 included confinement. The median confinement was 2.5 years. For Navy and Marine Corps Article 134 cases as a whole in the same years, the median was 1.7 years.

A quarter of the San Diego confinement sentences were 6 years or longer. These are adjudged sentences, the sentences announced at trial before any plea-agreement cap, clemency, or appeal. Each sentence covers every charge in the case, not only the Article 134 charge.

Sentence Lengths

Most convictions carried more than one year of confinement: 19 of 25, or 76%, compared with 56% across Navy and Marine Corps Article 134 cases. The most common sentence length in the table is more than 1 year but under 5 years, with 13 convictions (52%). Another 6 convictions (24%) carried 5 years or more.

Only 1 conviction had no confinement, a 4% share compared with 12% service-wide. Confinement under 6 months and confinement of 6 months to 1 year were both less common here than across the service.

Most Cases Were General Courts-Martial

Court level sets the maximum sentence. Only a general court-martial can impose more than one year of confinement or a dishonorable discharge. A special court-martial caps confinement at one year. It can impose a bad-conduct discharge but not a dishonorable discharge.

San Diego tried 22 of these cases at a general court-martial and 6 at a special court-martial. The general share of 79% was slightly higher than the 74% across the Navy and Marine Corps.

Punitive Discharges for Convicted Enlisted Members

For enlisted members, a punitive discharge is a bad-conduct or dishonorable discharge. Officers receive a dismissal instead. Of the 24 enlisted members convicted, 20 received a punitive discharge (83%), compared with 78% in Navy and Marine Corps-wide Article 134 cases. Of those 20, 13 were dishonorable discharges.

The group includes 1 convicted officer or warrant officer, who was not dismissed. A sentence without a punitive discharge does not rule out a later administrative separation, and these records do not track administrative separations.

What Else Was Charged?

In 14 of the 28 cases, at least one other article was charged with Article 134.

The most common other charge was Article 128 (assault), in 7 cases. Article 120 (sexual assault) was charged in 6. Article 120b (child sexual abuse), Article 120c (indecent recording and exposure), and Article 107 (false official statement) were charged in 3 each. A sentence covers every charge, so the long sentences in this group cover all the offenses in each case, not the general article alone.

Guilty Pleas and Contested Cases

Most of the accused pleaded guilty. Of the 28 accused, 22 pleaded guilty and 6 contested at least one charge. The contested share was 21%, about the same as the 24% across Navy and Marine Corps Article 134 cases in 2013–2018.

A case is contested when the accused pleads not guilty to at least one charge, with a full not-guilty plea or a mixed plea. Navy and Marine Corps records from before December 2020 often omit the plea, so these counts use only records that list it.

Rank of the Accused

Junior enlisted members, in grades E-1 to E-4, were 54% of the accused. NCOs were 43% and officers were 4%. Across the Navy and Marine Corps as a whole, junior enlisted members were 42% of those charged under Article 134. The San Diego group was more junior.

Cases by Year and the Rules in Force

The 28 cases were tried from January 2013 through November 2018. By year, there were 6 in 2013, 9 in 2014, 2 in 2015, 2 in 2016, 2 in 2017, and 7 in 2018. Together they were 10% of the 285 courts-martial at San Diego, California over the period.

Every case here came before the Military Justice Act of 2016 took effect on January 1, 2019. 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

Trial records show the charges, pleas, findings, and sentence. They do not show the evidence, the terms of any plea agreement, or the dates of the conduct. They also do not include matters handled through nonjudicial punishment or administrative action instead of a court-martial.

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.