§2E1.4 Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire: Federal Sentences, Fiscal Year 2024
In fiscal year 2024, 10 people were sentenced in federal court under guideline §2E1.4, "Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire." All 10 received a prison term, and the median was 85.5 months. No mandatory minimum applied to any of them, and 50% of the sentences we
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In brief: In fiscal year 2024, 10 people were sentenced in federal court under guideline §2E1.4, "Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire." All 10 received a prison term, and the median was 85.5 months. No mandatory minimum applied to any of them, and 50% of the sentences were within the guideline range.
This post uses the U.S. Sentencing Commission's records of 10 people sentenced in federal court in fiscal year 2024. 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 Median of 85.5 Months in a Group of 10
The U.S. Sentencing Commission counted 10 people in fiscal year 2024 whose primary guideline was §2E1.4. 10 of the 10 (100%) were sentenced to prison.
The median prison term was 85.5 months, or 7.1 years. A quarter received 97.5 months or more, and a quarter received 73.5 months or less. The all-years median under this guideline is 87 months, so fiscal year 2024 is slightly lower.
Plea and Trial Results
9 of the 10 people (90%) pleaded guilty, and 1 was convicted after a trial. The median prison term after a guilty plea was 84 months. The person convicted at trial received 120 months, which is a single case and not a pattern.
Among the 9 guilty pleas, 8 had a written plea agreement, and 1 was a straight plea with no agreement.
The plea rate of 90% is lower than the 93% for all years under this guideline. It is also lower than the 97% for everyone sentenced in federal court in fiscal year 2024.
No Mandatory Minimums and 50% Within the Range
A mandatory minimum prison term applied to 0 of the 10 people (0%). In fiscal year 2018, it applied to 4 of 11 people.
5 sentences (50%) were within the guideline range. 3 (30%) were below the range at the government's request, and 2 (20%) were below it without a government request. None were above the range.
The within-range share for all years under this guideline is 43%. For everyone sentenced in fiscal year 2024 under any guideline, it was 46%.
Supervised Release, Restitution, and Criminal History
9 people (90%) were ordered to serve supervised release, with a median term of 36 months. No fine was ordered, and restitution was ordered for 2 people (20%).
80% 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 2024 in the Yearly Table
The table lists each fiscal year from 2016 to 2025. Counts under this guideline range from 5 to 11 people, so each year is a small group.
For every guideline in fiscal year 2024, 61,678 people were sentenced, with a median prison term of 30 months. The §2E1.4 median was higher. Fiscal year 2024 ran from October 1, 2023 to September 30, 2024, and the Commission files these cases under the offense type Extortion/Racketeering.
| 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 Cannot Show
There is 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. It does not describe individual cases, and prison terms are those imposed, not time served. One year of 10 people is not a trend.
How We Counted
Everyone sentenced in federal court in fiscal year 2024 whose primary sentencing guideline was §2E1.4 (10), 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)
- §2E1.4 Use of Interstate Commerce Facilities in the Commission of Murder-For-Hire: Federal Sentences, FY2016–2025 (overview)
- 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.