§2E1.4 Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire: Federal Sentences, Fiscal Year 2016
In fiscal year 2016, 11 people were sentenced in federal court under guideline §2E1.4, "Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire." All 11 pleaded guilty and all 11 received a prison term, with a median of 66 months. That median is lower than the 87 months for all fi
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Trends › Federal Prosecution Analysis › §2E1.4 Use of Interstate Commerce Facilities in the Commissi › §2E1.4: FY2016
In brief: In fiscal year 2016, 11 people were sentenced in federal court under guideline §2E1.4, "Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire." All 11 pleaded guilty and all 11 received a prison term, with a median of 66 months. That median is lower than the 87 months for all fiscal years 2016 to 2025 under this guideline.
This post uses the U.S. Sentencing Commission's records of 11 people sentenced in federal court in fiscal year 2016. 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.
Pleas, Prison, and the 66-Month Median
Commission data for fiscal year 2016 include 11 people with §2E1.4 as the primary guideline, meaning it set the offense level for their most serious count. The Commission's broader category for these cases is Extortion/Racketeering.
11 of the 11 (100%) pleaded guilty, and none were convicted after a trial. 11 of the 11 (100%) were sentenced to prison, and none received probation only.
Among the 11, the median prison term was 66 months, which is 5.5 years. The top quarter of terms began at 100 months, and the bottom quarter ended at 57 months.
Most Sentences Were Below the Guideline Range at the Government's Request
7 of the 11 sentences (64%) were below the guideline range at the government's request. 3 (27%) were within the range. 1 (9%) was below the range without a government request, and none were above it.
In all years under this guideline, 43% of sentences were within the range. In fiscal year 2016, the within-range share was 27%, and the share for everyone sentenced in federal court under any guideline was 49%.
A mandatory minimum prison term applied to 2 of the 11 people (18%).
Plea Agreements, Supervised Release, and Money Orders
Among those who pleaded guilty, 91% had a written plea agreement, and 9% were straight pleas with no agreement.
All 11 people were ordered to serve supervised release after prison, with a median term of 36 months. A fine was ordered for 1 person (9%). Restitution was ordered for 0 people.
Criminal History
73% of the 11 people were in the lowest criminal history category, Category I. 18% were in the highest, Category VI.
Military records do not carry a criminal history field, so this measure has no court-martial equivalent here.
Context From Other Years and Other Guidelines
In fiscal year 2017, 11 people were sentenced under this guideline, and the median prison term was 87 months. The sentences within the range in that year were 64%.
The yearly table shows that counts under §2E1.4 ranged from 5 to 11 people. The 11 people in fiscal year 2016 are the largest group in the table, tied with fiscal years 2017 and 2018.
Fiscal year 2016 ran from October 1, 2015 to September 30, 2016. Across all guidelines that year, the Commission counted 67,742 people, with a median prison term of 24 months and a guilty plea rate of 97%. The §2E1.4 group had a higher median and a 100% plea rate.
| Fiscal year | People sentenced | Median prison | Pleaded guilty |
|---|---|---|---|
| 2016 | 11 | 66 months | 100% |
| 2017 | 11 | 87 months | 100% |
| 2018 | 11 | 120 months | 91% |
| 2019 | 6 | 92 months | 6 of 6 |
| 2020 | 6 | 63 months | 5 of 6 |
| 2021 | 7 | 106 months | 5 of 7 |
| 2022 | 9 | 93.5 months | 8 of 9 |
| 2023 | 6 | 90.5 months | 6 of 6 |
| 2024 | 10 | 85.5 months | 90% |
| 2025 | 5 | 84.5 months | 5 of 5 |
What the Records Leave Out
The approved crosswalk lists no close court-martial counterpart for §2E1.4, so only the federal figures appear in this post.
Only people who were convicted and sentenced appear in these records. Facts of individual cases are not included, and the prison terms are those imposed rather than time served. A single year with 11 people does not show a trend.
How We Counted
Everyone sentenced in federal court in fiscal year 2016 whose primary sentencing guideline was §2E1.4 (11), 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 (the background article)
- Federal Prosecution Analysis (all federal posts)
- How the Federal Comparison Data Was Built (sources and method)
- §2E1.4 Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire: Federal Sentences, FY2016–2025 (overview)
- §2E1.4 Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire: Federal Sentences, Fiscal Year 2017 (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.