> ## 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 2018 - URL: https://www.bodiesburied.com/trends/federal-guideline-2e2-1-making-or-financing-an-extortionate-extension-of-fy2018/ - Published: 2026-11-04T10:58:58.000Z - Updated: 2026-11-04T10:58:58.000Z - Description: Fiscal year 2018 had 18 people sentenced under §2E2.1, and 6 of them (33%) received a sentence above the guideline range. Of the 18, 16 (89%) received a prison term, with a median of 33 months (2.8 years). - 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: FY2018 **In brief:** Fiscal year 2018 had 18 people sentenced under §2E2.1, and 6 of them (33%) received a sentence above the guideline range. Of the 18, 16 (89%) received a prison term, with a median of 33 months (2.8 years). 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 18 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](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/). ## Sentences Above the Guideline Range In fiscal year 2018, 6 of the 18 sentences under §2E2.1 (33%) were above the guideline range. Within the range were 5 (28%), below the range without a government request were 5 (28%), and below the range at the government's request were 2 (11%). For all years of §2E2.1, 21% of sentences were within the range. For all guidelines in fiscal year 2018, the share was 51%. The share within the range for this guideline in fiscal year 2018 was 28%. In fiscal year 2017 it was 14%, and in fiscal year 2019 it was 25%. ## Prison Terms In all, 16 of the 18 people (89%) received a prison term, and 1 (6%) received probation only. The median prison term was 33 months. A quarter of those sent to prison received 72 months or more, and a quarter received 24 months or less. These are the terms imposed, not time served. Supervised release after prison was ordered for 15 people (83%), with a median term of 36 months. ## The Trial Sentence and the Guilty Pleas Of the 18 people, 17 (94%) pleaded guilty and 1 was convicted after a trial. The median prison term after a guilty plea was 30 months. The person convicted at trial and sent to prison received 120 months. That figure comes from 1 case and cannot be treated as a general result for trials. Among the guilty pleas, 94% had a written plea agreement and 6% were straight pleas with no agreement. No mandatory minimum prison term applied to any of the 18 people with that information recorded. ## Fines, Restitution, and Criminal History A fine was ordered for 2 people (11%), and restitution for 10 (56%). In the lowest criminal history category I were 44% of the group, and none were in the highest category VI. Court-martial records have no criminal history field. ## Defining the Guideline and the Count The Guidelines Manual titles §2E2.1 "Making or Financing an Extortionate Extension of Credit; Collecting an Extension of Credit by Extortionate Means". The U.S. Sentencing Commission places these 18 cases in its Extortion/Racketeering offense type. The primary guideline is the one that set the offense level for the most serious count. Federal fiscal year 2018 ran from October 1, 2017 to September 30, 2018\. Only people convicted and sentenced are included. ## The Rest of the Series In fiscal year 2017, 14 people were sentenced under this guideline, with a median prison term of 28 months. In fiscal year 2019, 16 people were sentenced, with a median of 29 months. Across fiscal years 2016 to 2025, 99 people were sentenced under §2E2.1\. Of those, 87% went to prison, the median prison term was 30 months, and 92% pleaded guilty. For all guidelines in fiscal year 2018, 69,425 people were sentenced, the median prison term was 24 months, and 97% pleaded guilty. The table lists each year. | 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 | ## What the Data Cannot Explain The records do not show the conduct behind any sentence, so they cannot explain why more sentences were above the range in this year. The crosswalk has no close court-martial counterpart for this guideline, so only federal numbers appear. ### How We Counted Everyone sentenced in federal court in fiscal year 2018 whose primary sentencing guideline was §2E2.1 (18), 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 2017](https://www.bodiesburied.com/trends/federal-guideline-2e2-1-making-or-financing-an-extortionate-extension-of-fy2017/) (previous or next fiscal year) - [§2E2.1 Making or Financing an Extortionate Extension of Credit: Federal Sentences, Fiscal Year 2019](https://www.bodiesburied.com/trends/federal-guideline-2e2-1-making-or-financing-an-extortionate-extension-of-fy2019/) (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.