§2E1.4 Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire: Federal Sentences, Fiscal Year 2017
Under guideline §2E1.4, "Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire," 11 people were sentenced in federal court in fiscal year 2017, and the median prison term was 87 months. That is the same as the median for all fiscal years 2016 to 2025 under this guideline. 64% of
· Understanding Trends in Military Practice · 6 min read
Trends › Federal Prosecution Analysis › §2E1.4 Use of Interstate Commerce Facilities in the Commissi › §2E1.4: FY2017
In brief: Under guideline §2E1.4, "Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire," 11 people were sentenced in federal court in fiscal year 2017, and the median prison term was 87 months. That is the same as the median for all fiscal years 2016 to 2025 under this guideline. 64% of the sentences were within the guideline range.
This post uses the U.S. Sentencing Commission's records of 11 people sentenced in federal court in fiscal year 2017. 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.
The 87-Month Median in Fiscal Year 2017
The U.S. Sentencing Commission counted 11 people in fiscal year 2017 whose primary guideline was §2E1.4. All 11 (100%) were sentenced to prison, and none received probation only.
The median prison term was 87 months, or 7.2 years. A quarter received 120 months or more, and a quarter received 60 months or less. These terms are the terms imposed, not time served.
The all-years median under this guideline is also 87 months, so fiscal year 2017 matches it. The all-years group has 82 people, and 96% of them were sent to prison.
Within the Range More Often Than in Neighboring Years
7 of the 11 sentences (64%) were within the guideline range. 4 (36%) were below the range at the government's request. None were below it without a government request, and none were above it.
The within-range share was higher than in fiscal year 2016, when it was 27%, and higher than in fiscal year 2018, when it was 18%. It was also higher than the 43% for all years under this guideline and the 49% for everyone sentenced in federal court in fiscal year 2017.
Every Case Ended in a Guilty Plea
11 of the 11 people (100%) pleaded guilty, and no one was convicted after a trial. Among those who pleaded guilty, 73% had a written plea agreement and 27% were straight pleas with no agreement.
A mandatory minimum prison term applied to 2 of the 11 people (18%).
Supervised Release, Restitution, and Criminal History
All 11 people were ordered to serve supervised release after prison, with a median term of 36 months. No fine was ordered. Restitution was ordered for 2 people (18%).
45% were in the lowest criminal history category, Category I, and 0% were in the highest, Category VI. Court-martial records have no criminal history field.
Fiscal Year 2017 Beside All Guidelines
For every guideline in fiscal year 2017, 66,873 people were sentenced. Their median prison term was 24 months, and 97% pleaded guilty. The §2E1.4 median was higher, and the plea rate was 100%.
Fiscal year 2017 ran from October 1, 2016 to September 30, 2017. The Commission files these cases under the offense type Extortion/Racketeering. The yearly table gives the medians for the years before and after: 66 months in fiscal year 2016 and 120 months in fiscal year 2018.
| 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 Cannot Be Concluded
The records have no close court-martial counterpart for this guideline in the approved crosswalk, so this post reports the federal numbers on their own.
The data counts only people who were convicted and sentenced, and the year has 11 people. A change in a few sentences would change the median and the percentages, so the numbers should not be read as a trend.
How We Counted
Everyone sentenced in federal court in fiscal year 2017 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 2016 (previous or next fiscal year)
- §2E1.4 Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire: Federal Sentences, Fiscal Year 2018 (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.