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# Article 134 at San Diego, California Before and After 2019
- URL: https://www.bodiesburied.com/trends/san-diego-california-article-134-before-after-2019/
- Published: 2026-10-28T06:32:35.000Z
- Updated: 2026-10-28T08:23:03.000Z
- Description: San Diego, California tried 25 courts-martial charging Article 134, the general article, from 2019 to 2023. Of cases with a plea recorded, 32% were contested, compared with 30% in Navy and Marine Corps Article 134 cases overall. All 25 ended in a conviction with confinement.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, San Diego, California, Article 134, 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 134

**Short answer:** San Diego, California tried 25 courts-martial charging Article 134, the general article, from 2019 to 2023\. Of cases with a plea recorded, 32% were contested, compared with 30% in Navy and Marine Corps Article 134 cases overall. All 25 ended in a conviction with confinement. The median confinement was 1 year, compared with 1.5 years service-wide and 2.5 years at San Diego in 2013–2018.

Based on 25 cases · 2019–2023 · Navy and Marine Corps records · data updated October 24, 2026

## Every Case Ended in Confinement

All 25 cases ended in a conviction on at least one charge, and all 25 sentences included confinement (100%). Across Navy and Marine Corps Article 134 cases in the same years, 11% of convictions had no confinement. At San Diego in 2013–2018, 96% of convictions included confinement.

Confinement was shorter than in the service as a whole. Confinement under 6 months was 40% of convictions, compared with 20% service-wide. Confinement of 6 months to 1 year was 24%, compared with 17%. Of the 25 convictions, 9 (36%) carried more than one year, compared with 52%. Confinement of more than 1 year but under 5 years was 28% here, compared with 42%. Confinement of 5 years or more was 8%, compared with 10%. A quarter of sentences were 1.9 years or longer.

These are adjudged sentences, set at trial before any plea-agreement cap, clemency, or appeal. Each covers every charge in the case.

| Adjudged confinement            | Convictions | Share here | Share, all Navy and Marine Corps Article 134 cases in 2019–2023 |
| ------------------------------- | ----------- | ---------- | --------------------------------------------------------------- |
| No confinement                  | 0           | 0%         | 11%                                                             |
| Under 6 months                  | 10          | 40%        | 20%                                                             |
| 6 months to 1 year              | 6           | 24%        | 17%                                                             |
| More than 1 year, under 5 years | 7           | 28%        | 42%                                                             |
| 5 years or more                 | 2           | 8%         | 10%                                                             |

## More Contested Cases, No Full Acquittals

A case is contested when the accused pleads not guilty to at least one charge. Of the 25 cases, 8 had not-guilty or mixed pleas and 17 had guilty pleas. The contested share was 32%, compared with 30% in Navy and Marine Corps Article 134 cases overall.

None of the 8 contested cases that reached a verdict ended in a full acquittal (0 of 8). In 2013–2018, 3 of 6 did.

## Sentences Were Shorter Than Before

The median confinement went from 2.5 years in 2013–2018 to 1 year in 2019–2023\. The later figure is shorter than the 1.5 years median in all Navy and Marine Corps Article 134 cases. Punitive discharges for convicted enlisted members went from 83% to 70%. The share of cases tried at a general court-martial went from 79% to 68%.

Counting full years only, there were about 5 cases a year in both periods. These groups are small, and a few cases can change a rate. The figures show direction, not precise change.

|                                     | 2013–2018 | 2019–2023 |
| ----------------------------------- | --------- | --------- |
| Cases                               | 28        | 25        |
| Contested (of pleas recorded)       | 21%       | 32%       |
| Full acquittals (decided contested) | 3 of 6    | 0 of 8    |
| Convictions with confinement        | 96%       | 100%      |
| Median confinement                  | 2.5 years | 1 year    |
| Punitive discharge (enlisted)       | 83%       | 70%       |
| General courts-martial              | 79%       | 68%       |

## Punitive Discharges and Dismissals

A punitive discharge is a bad-conduct or dishonorable discharge for an enlisted member, or a dismissal for an officer. Of 23 convicted enlisted members, 16 received one: 10 bad-conduct discharges and 6 dishonorable discharges. In Navy and Marine Corps-wide Article 134 cases, the rate was 74%. 2 convicted officers or warrant officers appear here, and 1 was dismissed.

A sentence without a punitive discharge does not rule out an administrative separation afterward.

## Obstruction, Attempts, and Other Charges

Article 134 was the only charge in 11 of the 25 cases. Across all Navy and Marine Corps Article 134 cases in 2019–2023, 125 of 346 charged it alone. The most common other charges were Article 131b (obstruction) and Article 80 (attempt), in 4 cases each. Article 120b (child sexual abuse) and Article 92 (orders violation) were charged in 3 each, and Article 117a (intimate image) in 2\. Each sentence covers every charge in the case, so these other charges are part of the confinement and discharge figures.

## The Accused Were More Senior

Junior enlisted members (E-1 to E-4) were 48% of the accused here, NCOs were 44%, and officers were 8%. Across all Navy and Marine Corps Article 134 cases in 2019–2023, junior enlisted members were 61% of the accused.

General courts-martial, which can impose long confinement and a dishonorable discharge, tried 68% of these cases (17 of 25). Special courts-martial, which cap confinement at one year and cannot impose a dishonorable discharge, tried the rest.

## Cases by Year

The records hold cases from April 2019 to December 2023\. By year, there were 2 in 2019, 1 in 2020, 8 in 2021, 6 in 2022, and 8 in 2023\. These cases were 14% of the 173 courts-martial at San Diego in 2019–2023.

## What the Records Cannot Show

The records give trial dates, not offense dates. They do not describe the evidence or plea terms. They do not include nonjudicial punishment or administrative separations. Navy and Marine Corps records before December 2020 often omit the plea and forum, so those counts use only records that list them. This affects trials before that date most, including the earlier comparison period.

For what the offense covers and how it is defended, see [Article 134 on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-134/?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 134 (found guilty, not guilty, or both): 2013–2018 (28) and 2019–2023 (25). Comparisons use every Navy and Marine Corps case charging Article 134 in 2019–2023.

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 134 (General Article): Court-Martial Data and Trends](https://www.bodiesburied.com/trends/article-134-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)
- [General Article Cases at Camp Lejeune, North Carolina: 2017–2018 vs. 2019–2023](https://www.bodiesburied.com/trends/camp-lejeune-north-carolina-article-134-before-after-2019/) (same offense, another installation)
- [General Article Cases at Camp Pendleton, California: 2017–2018 vs. 2019–2023](https://www.bodiesburied.com/trends/camp-pendleton-california-article-134-before-after-2019/) (same offense, another installation)
- [Is Navy-Marine Corps General Article Prosecution Rising or Falling? Article 134, 2017–2025](https://www.bodiesburied.com/trends/navy-marine-corps-article-134-trend-2017-2025/)
- [Article 134 explained on the law firm's website](https://www.ucmj-defender.com/practice-areas/court-martial/article-134/?ref=bodiesburied.com)
- [Search every case in Military Trial Results](https://www.bodiesburied.com/military-trial-results/) (members)

Next: [Article 134 at San Diego, California Before and After 2024](https://www.bodiesburied.com/trends/san-diego-california-article-134-before-after-2024/) →

## Military Judges Who Presided Over Article 134 Cases at San Diego, California, 2019–2023

- [Andrea Goode](https://www.bodiesburied.com/judge-andrea-goode/)
- [Philip Hamon](https://www.bodiesburied.com/judge-philip-hamon/)
- [Andrea Lockhart](https://www.bodiesburied.com/judge-andrea-lockhart/)
- [Michelle Pettit](https://www.bodiesburied.com/judge-michelle-pettit/)
- [Ryan Stormer](https://www.bodiesburied.com/judge-ryan-stormer/)
- [Chad Temple](https://www.bodiesburied.com/judge-chad-temple/)

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.

**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.