Article 134 at San Diego, California Before and After 2024

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Based on 26 cases · 2024–2026 · Navy and Marine Corps records · data updated October 24, 2026

The Earlier and Later Periods

Counting full years only, the earlier period had about 5 cases a year and the later period has had about 10 a year. The 2024–2026 cases were 15 in 2024, 6 in 2025, and 5 so far in 2026, which is a partial year. Together they were 21% of the 126 courts-martial at San Diego in 2024–2026.

Sentence measures changed in different directions. Every conviction in 2019–2023 included confinement (100%), compared with 76% since. Among sentences that included confinement, the median went from 1 year to 1.2 years. Punitive discharges for enlisted members went from 70% to 61%. The general court-martial share went from 68% to 62%.

These groups are small, and a few cases can change a rate. The figures show direction, not precise change.

Why the Periods Are Divided at 2024

2 rule changes took effect at the start of 2024. Since December 28, 2023, special trial counsel, not commanders, decide whether to prosecute covered offenses such as sexual assault, domestic violence, and murder. When every guilty finding in a case is for an offense after December 27, 2023, the military judge sets the sentence within new sentencing parameters.

Both rules depend on when the offense happened, and the records give only trial dates. Trials from 2024 on therefore mix cases under old and new rules. The changes above happened in the same period as these rule changes. The records cannot show whether the rule changes caused any of them.

Sentences in 2024–2026

Of 26 cases, 25 ended in a conviction on at least one charge. Of those sentences, 19 included confinement (76%). The median confinement was 1.2 years, shorter than the 1.5-year median across Navy and Marine Corps Article 134 cases in the same years. A quarter of the confinement sentences were 5 years or longer.

Sentences longer than one year were 10 of 25 convictions (40%), compared with 45% service-wide for this article. These are adjudged sentences, set at trial before any plea-agreement cap, clemency, or appeal, and they cover every charge in the case.

General and Special Courts-Martial Had Very Different Sentences

The 2024–2026 cases were 16 general courts-martial and 10 special courts-martial. The median confinement was 3 years at general courts-martial and 2 months at special courts-martial. The contested share was 20% at general courts-martial and 40% at special courts-martial.

A general court-martial can impose any lawful sentence, including long confinement and a dishonorable discharge. A special court-martial caps confinement at one year and cannot impose a dishonorable discharge. The general share here, 62%, was about the same as the 65% across the rest of the Navy and Marine Corps.

Punitive Discharges Since 2024

Of 23 convicted enlisted members, 14 received a bad-conduct or dishonorable discharge (61%). That is less often than the 75% across Navy and Marine Corps Article 134 cases. Of those 14, 9 were dishonorable discharges.

1 convicted officer or warrant officer appears here and was not dismissed. A sentence without a punitive discharge does not rule out a later administrative separation.

Pleas and Full Acquittals

A contested case is one where the accused pleads not guilty to at least one charge. Of 25 records that list the plea, 18 were guilty pleas and 7 were contested. The contested share was 28%, about the same as the 29% service-wide. In the earlier period, the share was 32%.

Few contested cases ended in a full acquittal in either period: 0 of 8 contested cases that reached a verdict in 2019–2023 and 1 of 7 in 2024–2026. There were few contested cases, so 1 verdict changes these figures. The records do not describe the evidence in any of them.

Other Charges and Rank

Article 134 is the general article. Only 12 of the 26 cases charged another article as well. Article 120b (child sexual abuse) was charged in 3 cases. Article 80 (attempt), Article 128 (assault), and Article 112a (drug) were charged in 2 each, and Article 108 (military property) in 1.

By rank, the accused were 18 junior enlisted members, 6 NCOs, and 1 officer. That mix is more junior than Navy and Marine Corps Article 134 cases overall, where 63% were junior enlisted.

What the Records Cannot Show

Trial records show charges, pleas, findings, and sentences. They do not show the evidence, the plea terms, the offense dates, or conduct handled through nonjudicial punishment or administrative separation.

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.