§2E1.4 Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire: Federal Sentences, Fiscal Year 2018
In fiscal year 2018, the median prison term under guideline §2E1.4, "Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire," was 120 months for the 11 people sentenced. That is the highest median in the yearly table for this guideline. Only 18% of the sentences were within the g
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Trends › Federal Prosecution Analysis › §2E1.4 Use of Interstate Commerce Facilities in the Commissi › §2E1.4: FY2018
In brief: In fiscal year 2018, the median prison term under guideline §2E1.4, "Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire," was 120 months for the 11 people sentenced. That is the highest median in the yearly table for this guideline. Only 18% 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 2018. 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.
A 120-Month Median for 11 People
In fiscal year 2018, 11 people were sentenced with §2E1.4 as the primary guideline, and every one of them (100%) received a prison term.
The median was 120 months, or 10 years. The highest quarter of terms began at 137 months, and the lowest quarter ended at 84 months.
The median for all fiscal years 2016 to 2025 under this guideline is 87 months. The fiscal year 2017 median was also lower, at 87 months.
Mandatory Minimums and Criminal History
A mandatory minimum prison term applied to 4 of the 11 people (36%). In fiscal years 2016 and 2017, it applied to 2 of 11 (18%) in each year.
The criminal history pattern was also different. 27% of the 11 people were in the lowest category, Category I, and 27% were in the highest, Category VI. Court-martial records lack a criminal history field.
Guideline Range Positions
2 sentences (18%) were within the guideline range. 4 (36%) were below the range at the government's request, and 4 (36%) were below it without a government request. 1 (9%) was above the range.
The within-range share of 18% was lower than the 64% in fiscal year 2017, the 43% for all years under this guideline, and the 51% for everyone sentenced in federal court in fiscal year 2018.
One Trial Conviction
10 of the 11 people (91%) pleaded guilty, and 1 was convicted after a trial. The median prison term after a guilty plea was 120 months. The person convicted at trial received 470 months.
Because the trial group is a single person, that figure does not describe trial sentences in general. Among those who pleaded guilty, 90% had a written plea agreement, and 10% were straight pleas with no agreement.
Supervised Release and Restitution
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 4 people (36%).
Fiscal Year 2018 Compared With All Guidelines
Across all guidelines in fiscal year 2018, the total was 69,425 people, with a median of 24 months and a 97% guilty plea rate. The §2E1.4 median was higher, and its plea rate was 91%.
Fiscal year 2018 ran from October 1, 2017 to September 30, 2018. The Commission files these cases under the offense type Extortion/Racketeering. The table shows every year for this guideline.
| 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 |
Limits on These Numbers
The crosswalk has no close court-martial match for §2E1.4. The numbers here are federal only.
People who were acquitted or whose cases were dismissed are not in this data. Prison terms are imposed terms, not time served. The records give no reason for the differences between years, and 11 people is a small group.
How We Counted
Everyone sentenced in federal court in fiscal year 2018 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.