Electronic Media Not Chargeable Under Article 121

In an interesting case - United States v. Stevens, __ M.J. __, No. 201400330 (N-M. Ct. Crim. App. Nov. 10, 2105) The Navy-Marine Corps Court of Criminal Appeals ruled that electronic media without a tangible form do not fall within the definition of Article 121.

Basically, the accused pleaded guilty to using a stolen credit card to steal an audiobook, music downloads, video games on his PlayStation, and electronic currency for a video game.


The court found no further guidance in military case law on whether electronic media as alleged would be the object of larceny under Article 121. This seems to be a case the Court of Appeals for the Armed Forces is sure to hear.