> ## 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. # §2E2.1 Making or Financing an Extortionate Extension of Credit: Federal Sentences, Fiscal Year 2017 - URL: https://www.bodiesburied.com/trends/federal-guideline-2e2-1-making-or-financing-an-extortionate-extension-of-fy2017/ - Published: 2026-11-04T10:58:57.000Z - Updated: 2026-11-04T10:58:57.000Z - Description: In fiscal year 2017, 14 people were sentenced under §2E2.1, and only 2 sentences (14%) were within the guideline range. Below the range without a government request were 7 (50%). The median prison term was 28 months (2.3 years), and 11 people (79%) received prison terms. - Author: Jocelyn C. Stewart - Tags: Understanding Trends, Federal [Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › [§2E2.1 Making or Financing an Extortionate Extension of Cred](https://www.bodiesburied.com/trends/federal-guideline-2e2-1-making-or-financing-an-extortionate-extension-of/) › §2E2.1: FY2017 **In brief:** In fiscal year 2017, 14 people were sentenced under §2E2.1, and only 2 sentences (14%) were within the guideline range. Below the range without a government request were 7 (50%). The median prison term was 28 months (2.3 years), and 11 people (79%) received prison terms. 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 14 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](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/). ## Few Sentences Were Within the Guideline Range In fiscal year 2017, 2 of the 14 sentences under §2E2.1 (14%) were within the guideline range. Below the range without a government request were 7 (50%). Below the range at the government's request were 4 (29%), and above the range was 1 (7%). The all-years share within the range for this guideline is 21%, and the all-guidelines share for fiscal year 2017 is 49%. The share in fiscal year 2017 was lower than both. In fiscal year 2016 it was 45%, and in fiscal year 2018 it was 28%. ## Prison Terms and Probation In all, 11 of the 14 people (79%) received a prison term, and 2 (14%) received probation only. Probation only means no prison and no other confinement. The median prison term was 28 months. The top quarter of prison terms were 60 months or more, and the bottom quarter were 24 months or less. Courts impose these terms, and the data does not show time served. The court ordered 10 people (71%) to serve supervised release after prison, with a median term of 36 months. ## Guilty Pleas and Agreements Of the 14 people, 13 (93%) pleaded guilty and 1 was convicted after a trial. The median prison term after a guilty plea was 27 months. The person convicted at trial and sent to prison received 28 months, which is close, but 1 trial case supports no general comparison. Among the guilty pleas, 92% had a written plea agreement and 8% were straight pleas with no agreement. No mandatory minimum prison term applied to any of the 14 people with that information recorded. ## Fines, Restitution, and Criminal History Fines were ordered for 6 people (43%) and restitution for 4 (29%). In the lowest criminal history category I were 57% of the group, and none were in the highest category VI. Court-martial records have no criminal history field. ## What §2E2.1 Is and How the Year Was Counted The Guidelines Manual titles §2E2.1 "Making or Financing an Extortionate Extension of Credit; Collecting an Extension of Credit by Extortionate Means". All 14 cases are classed as Extortion/Racketeering by the Commission. A person is counted once, under whichever guideline set the offense level for the most serious count. Dates for this fiscal year are October 1, 2016 through September 30, 2017\. The data does not include acquittals or dismissals. ## Years Before and After, and the Federal Total The adjacent years are fiscal year 2016 (11 people, median 24 months) and fiscal year 2018 (18 people, median 33 months). The all-years record for §2E2.1 covers 99 people, of whom 87% went to prison, with a median prison term of 30 months and 92% guilty pleas. Fiscal year 2017 for every guideline covered 66,873 people, with a median of 24 months and 97% guilty pleas. Each year appears in the table. | Fiscal year | People sentenced | Median prison | Pleaded guilty | | ----------- | ---------------- | ------------- | -------------- | | 2016 | 11 | 24 months | 91% | | 2017 | 14 | 28 months | 93% | | 2018 | 18 | 33 months | 94% | | 2019 | 16 | 29 months | 94% | | 2020 | 7 | 33 months | 7 of 7 | | 2021 | 9 | 15 months | 9 of 9 | | 2022 | 4 | 0 months | 4 of 4 | | 2023 | 9 | 35 months | 8 of 9 | | 2024 | 8 | 33 months | 6 of 8 | | 2025 | 3 | 37 months | 2 of 3 | ## Limits Nothing in the records explains any sentence, and no case facts are included. No close court-martial counterpart exists in the crosswalk, so these federal numbers are not compared with military cases. ### How We Counted Everyone sentenced in federal court in fiscal year 2017 whose primary sentencing guideline was §2E2.1 (14), 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](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) - [§2E2.1 Making or Financing an Extortionate Extension of Credit: Federal Sentences, FY2016–2025](https://www.bodiesburied.com/trends/federal-guideline-2e2-1-making-or-financing-an-extortionate-extension-of/) (overview) - [§2E2.1 Making or Financing an Extortionate Extension of Credit: Federal Sentences, Fiscal Year 2016](https://www.bodiesburied.com/trends/federal-guideline-2e2-1-making-or-financing-an-extortionate-extension-of-fy2016/) (previous or next fiscal year) - [§2E2.1 Making or Financing an Extortionate Extension of Credit: Federal Sentences, Fiscal Year 2018](https://www.bodiesburied.com/trends/federal-guideline-2e2-1-making-or-financing-an-extortionate-extension-of-fy2018/) (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.