§2A2.4 Obstructing or Impeding Officers: Federal Sentences, Fiscal Year 2019
In fiscal year 2019, 181 of the 206 people sentenced under §2A2.4 (88%) received a prison term, with a median of 12 months. Sentences within the guideline range went to 55% (113). The median was 12 months after a guilty plea and 12.5 months after a trial.
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In brief: In fiscal year 2019, 181 of the 206 people sentenced under §2A2.4 (88%) received a prison term, with a median of 12 months. Sentences within the guideline range went to 55% (113). The median was 12 months after a guilty plea and 12.5 months after a trial.
This post uses the U.S. Sentencing Commission's records of 206 people sentenced in federal court in fiscal year 2019. Acquittals and dismissals come from a second source, the Federal Judicial Center's records of 753,808 federal defendants whose cases ended in fiscal years 2016 to 2025. It is part of the Federal Prosecution Analysis series, which builds on Military Moves Toward Sentencing Guidelines to Mirror the Federal System. How the numbers were built: How the Federal Comparison Data Was Built.
Prison Terms in Fiscal Year 2019
The Sentencing Commission counted 206 people in fiscal year 2019 whose primary guideline was §2A2.4. Prison was imposed on 181 (88%), and probation only, with no prison or other confinement, on 21 (10%).
The median prison term was 12 months. A quarter of those sent to prison received 20 months or more, and a quarter received 8 months or less.
Supervised release was ordered for 149 people (72%), with a median term of 36 months. A fine was ordered for 16 (8%), and restitution for 20 (10%).
Guilty Pleas Compared With Trials
There were 195 guilty pleas (95%) and 11 convictions after trial. The median prison term was 12 months after a guilty plea and 12.5 months after a trial.
The trial median is based on 10 people sent to prison. The data shows little difference between the plea and trial medians in this year, but a group of 10 is too small to establish a pattern.
Of the guilty pleas, 79% had a written plea agreement and 19% were straight pleas with no agreement.
Within the Range or Not
All 206 people had range information. Within the range were 113 (55%). Below the range at the government's request were 34 (17%), and below the range without a government request were 47 (23%). Above the range were 12 (6%).
The year before, 2018, had 54% within the range. The year after, 2020, had 57%. Over 2016 to 2025, §2A2.4 had 57%, and all federal cases in fiscal year 2019 had 51%.
Mandatory Minimums and Criminal History
No mandatory minimum prison term applied to any of the 201 people with that information recorded (0 of 201).
In criminal history, 44% of people were in category I, the lowest, and 12% were in category VI, the highest. Court-martial records have no criminal history field.
Guideline, Fiscal Year, and National Context
In the Guidelines Manual, §2A2.4 is titled "Obstructing or Impeding Officers". The Commission lists all 206 cases under the Administration of Justice offense type.
The fiscal year began on October 1, 2018 and ended on September 30, 2019. All federal cases that year, under every guideline, totaled 76,538 people, with a median prison term of 21 months and 98% guilty pleas.
From 2016 to 2025, §2A2.4 covered 2,105 people. Of them, 86% were sent to prison and 92% pleaded guilty. The table lists each year's count.
| Fiscal year | People sentenced | Median prison | Pleaded guilty |
|---|---|---|---|
| 2016 | 179 | 12 months | 95% |
| 2017 | 166 | 12 months | 97% |
| 2018 | 239 | 12 months | 90% |
| 2019 | 206 | 12 months | 95% |
| 2020 | 185 | 12 months | 96% |
| 2021 | 177 | 12 months | 98% |
| 2022 | 247 | 12 months | 95% |
| 2023 | 246 | 12 months | 87% |
| 2024 | 248 | 10 months | 85% |
| 2025 | 212 | 12 months | 89% |
Limits of the Records
Acquittals and dismissals are not in the Commission's sentencing files, so these figures describe only people who were convicted. Prison terms shown are the terms imposed.
This guideline has no close court-martial counterpart in the crosswalk. The post therefore reports federal numbers on their own and leaves the facts of individual cases out.
How We Counted
Everyone sentenced in federal court in fiscal year 2019 whose primary sentencing guideline was §2A2.4 (206), U.S. Sentencing Commission individual data files. The primary guideline is the one that set the offense level for the most serious count.
Federal fiscal years run from October 1 to September 30. No person, judge, or lawyer is identified in any of these records.
What to Keep in Mind
No parole in federal prison; credit for good conduct. Federal prison has no parole for crimes committed on or after November 1, 1987. A federal prisoner can earn up to 54 days of good conduct credit for each year of the sentence the judge imposed, which is about 15%. Some federal prisoners can also earn First Step Act time credits, but many offenses make a person ineligible. The numbers in this post are the sentences judges imposed, not the time people actually served.
Federal supervised release. Most federal prison sentences are followed by a term of supervised release that the judge sets as part of the sentence. A person who violates it can be sent back to prison. A court-martial cannot sentence anyone to supervision after release. Military parole and mandatory supervised release are decided later by a board, not by the judge at trial.
Who decides the sentence, and under what rules. Federal judges sentence every federal case. They must calculate the Sentencing Guidelines range, which is advisory, and must impose any mandatory minimum the statute requires unless an exception applies. In courts-martial, the accused could choose sentencing by members until the rules changed. For cases in which every guilty finding is for an offense committed after December 27, 2023, a military judge sentences alone, within sentencing parameters. Courts-martial tried in 2024 and later include both old-rule and new-rule cases, and the data cannot tell them apart.
Time periods. Federal numbers are by federal fiscal year (October 1 to September 30), based on the sentencing date. The military numbers are by trial date. Neither source has the date of the offense, so a change in law shows up in either data set gradually.
How life sentences and "time served" are counted. In the federal numbers, a life sentence is counted as 470 months, and any other sentence longer than 470 months is counted as just under 470 months. A sentence of "time served" is counted as one day (0.03 months). Averages are affected by these rules; medians much less.
Related Analysis
- Military Moves Toward Sentencing Guidelines to Mirror the Federal System (the background article)
- Federal Prosecution Analysis (all federal posts)
- How the Federal Comparison Data Was Built (sources and method)
- §2A2.4 Obstructing or Impeding Officers: Federal Sentences, FY2016–2025 (overview)
- §2A2.4 Obstructing or Impeding Officers: Federal Sentences, Fiscal Year 2018 (previous or next fiscal year)
- §2A2.4 Obstructing or Impeding Officers: Federal Sentences, Fiscal Year 2020 (previous or next fiscal year)
- How Often Federal Judges Sentence Outside the Guideline Range
- Mandatory Minimums: How Many Federal Sentences Are Set by Congress
- U.S. Sentencing Commission, Individual Offender Datafiles (source)
- Federal Judicial Center, Integrated Database (criminal defendants) (source)
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.