> ## Content Index > Fetch the complete content index at: https://www.bodiesburied.com/llms.txt > Use this file to discover other available public pages before exploring further. # §2A6.1 Threatening or Harassing Communications: Federal Sentences, Fiscal Year 2023 - URL: https://www.bodiesburied.com/trends/federal-guideline-2a6-1-threatening-or-harassing-communications-fy2023/ - Published: 2026-11-04T10:24:57.000Z - Updated: 2026-11-04T10:24:57.000Z - Description: In fiscal year 2023, 146 of the 163 people sentenced under §2A6.1 (90%) received a prison term. The median prison term was 18 months, and 78 people (48%) were sentenced within the guideline range. - Author: Jocelyn C. Stewart - Tags: Understanding Trends, Federal [Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › [§2A6.1 Threatening or Harassing Communications](https://www.bodiesburied.com/trends/federal-guideline-2a6-1-threatening-or-harassing-communications/) › §2A6.1: FY2023 **In brief:** In fiscal year 2023, 146 of the 163 people sentenced under §2A6.1 (90%) received a prison term. The median prison term was 18 months, and 78 people (48%) were sentenced within the guideline range. Updated November 4, 2026 · Sources: U.S. Sentencing Commission and Federal Judicial Center, fiscal years 2016–2025 This post uses the U.S. Sentencing Commission's records of 163 people sentenced in federal court in fiscal year 2023\. 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](https://www.bodiesburied.com/trends/federal/) series, which builds on [Military Moves Toward Sentencing Guidelines to Mirror the Federal System](https://www.bodiesburied.com/trends/military-sentencing-guidelines-federal-system/). How the numbers were built: [How the Federal Comparison Data Was Built](https://www.bodiesburied.com/trends/federal-data-methodology/). ## 90% Were Sentenced to Prison 146 of 163 people (90%) were sentenced to prison, and 13 (8%) received probation only, with no prison or other confinement. For all guidelines in fiscal year 2023, 64,124 people were sentenced, and the median prison term was 30 months. Under §2A6.1, the median prison term was 18 months. A quarter of those sent to prison received 30 months or more, and a quarter received 10 months or less. ## Which Cases Belong to §2A6.1 The Guidelines Manual title is "Threatening or Harassing Communications; Hoaxes; False Liens." The Sentencing Commission counts all 163 cases in its Stalking/Harassing offense type. Fiscal year 2023 ran from October 1, 2022 to September 30, 2023\. A case is counted here only if the person was convicted and sentenced, and only if §2A6.1 set the offense level for the most serious count. ## Plea Agreements and Trial Cases 149 people (91%) pleaded guilty, and 14 were convicted after a trial. 91% of the guilty pleas had a written plea agreement, and 9% were straight pleas. The median prison term after a guilty plea was 16 months. After a trial it was 41.5 months, based on 14 people. The records do not show what differences between the cases account for the gap. ## The Guideline Range in Fiscal Year 2023 The sentence's position was recorded for 162 people. 78 (48%) were within the range. 26 (16%) were below it at the government's request, 42 (26%) were below it without a request, and 16 (10%) were above it. In fiscal year 2022 the §2A6.1 share within the range was 43%, and in fiscal year 2024 it was 48%. Across all guidelines in fiscal year 2023 it was 42%. A mandatory minimum prison term applied to 1 of the 162 people (less than 1%). ## Supervised Release, Fines, and Criminal History 142 people (87%) were ordered to serve supervised release after prison, with a median term of 36 months. A fine was ordered for 14 (9%), and restitution for 13 (8%). 52% were in the lowest criminal history category and 11% in the highest. Court-martial records have no criminal history field. ## How the Yearly Medians Compare The median was 18 months in fiscal year 2022, 18 months in fiscal year 2023, and 20 months in fiscal year 2024\. The counts were 184 people, 163 people, and 176 people. The table gives all years. From fiscal years 2016 to 2025, 1,558 people were sentenced under §2A6.1\. 87% went to prison, the median was 18 months, and 92% pleaded guilty. | Fiscal year | People sentenced | Median prison | Pleaded guilty | | ----------- | ---------------- | ------------- | -------------- | | 2016 | 135 | 18 months | 93% | | 2017 | 116 | 20 months | 91% | | 2018 | 146 | 24 months | 90% | | 2019 | 137 | 18 months | 90% | | 2020 | 154 | 18 months | 91% | | 2021 | 159 | 15 months | 96% | | 2022 | 184 | 18 months | 91% | | 2023 | 163 | 18 months | 91% | | 2024 | 176 | 20 months | 92% | | 2025 | 188 | 20 months | 93% | ## Limits The approved crosswalk lists no close court-martial counterpart for §2A6.1, so the post reports federal numbers only. The prison terms are terms imposed, not time served. The data shows outcomes for groups, not the facts or the reasons in any one case. ### How We Counted Everyone sentenced in federal court in fiscal year 2023 whose primary sentencing guideline was §2A6.1 (163), 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. **Mandatory minimum sentences.** Many federal statutes on drugs, images of child exploitation, child sex abuse, and firearms carry mandatory minimum prison terms. The UCMJ has mandatory minimums only for a few offenses (a dishonorable discharge or dismissal for rape and sexual assault, and life for premeditated murder). Federal sentences for these offenses are partly set by Congress, not by the judge. ## Related Analysis - [Military Moves Toward Sentencing Guidelines to Mirror the Federal System](https://www.bodiesburied.com/trends/military-sentencing-guidelines-federal-system/) (the background article) - [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) (all federal posts) - [How the Federal Comparison Data Was Built](https://www.bodiesburied.com/trends/federal-data-methodology/) (sources and method) - [§2A6.1 Threatening or Harassing Communications: Federal Sentences, FY2016–2025](https://www.bodiesburied.com/trends/federal-guideline-2a6-1-threatening-or-harassing-communications/) (overview) - [§2A6.1 Threatening or Harassing Communications: Federal Sentences, Fiscal Year 2022](https://www.bodiesburied.com/trends/federal-guideline-2a6-1-threatening-or-harassing-communications-fy2022/) (previous or next fiscal year) - [§2A6.1 Threatening or Harassing Communications: Federal Sentences, Fiscal Year 2024](https://www.bodiesburied.com/trends/federal-guideline-2a6-1-threatening-or-harassing-communications-fy2024/) (previous or next fiscal year) - [How Often Federal Judges Sentence Outside the Guideline Range](https://www.bodiesburied.com/trends/federal-sentences-outside-guideline-range/) - [Mandatory Minimums: How Many Federal Sentences Are Set by Congress](https://www.bodiesburied.com/trends/federal-mandatory-minimum-sentences/) - [U.S. Sentencing Commission, Individual Offender Datafiles](https://www.ussc.gov/research/datafiles/commission-datafiles?ref=bodiesburied.com) (source) - [Federal Judicial Center, Integrated Database (criminal defendants)](https://www.fjc.gov/research/idb?ref=bodiesburied.com) (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](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.