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# §2H4.1 Peonage, Involuntary Servitude, and Slave Trade: Federal Sentences, Fiscal Year 2023
- URL: https://www.bodiesburied.com/trends/federal-guideline-2h4-1-peonage-involuntary-servitude-and-slave-trade-fy2023/
- Published: 2026-11-04T10:58:46.000Z
- Updated: 2026-11-04T10:58:46.000Z
- Description: Federal courts sentenced 16 people in fiscal year 2023 whose primary guideline was §2H4.1, "Peonage, Involuntary Servitude, and Slave Trade." Every one of them received a prison term, with a median of 65 months. That median is lower than the 72 months across fiscal years 2016 to 2025 and lower than
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Federal

[Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › [§2H4.1 Peonage, Involuntary Servitude, and Slave Trade](https://www.bodiesburied.com/trends/federal-guideline-2h4-1-peonage-involuntary-servitude-and-slave-trade/) › §2H4.1: FY2023

**In brief:** Federal courts sentenced 16 people in fiscal year 2023 whose primary guideline was §2H4.1, "Peonage, Involuntary Servitude, and Slave Trade." Every one of them received a prison term, with a median of 65 months. That median is lower than the 72 months across fiscal years 2016 to 2025 and lower than the 87 months in fiscal year 2024.

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 16 people sentenced in federal court in fiscal year 2023\. 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/).

## Prison Terms in Fiscal Year 2023

All 16 people (100%) were sentenced to prison, and none received probation only. The median prison term was 65 months, or 5.4 years. A quarter of the group received 101.5 months or more, and a quarter received 45.3 months or less.

The Commission lists these cases under the offense type Individual Rights. The data counts only people who were convicted and sentenced, so acquittals and dismissals are not included. Prison terms are the terms imposed, not time served.

## Plea Versus Trial

13 of the 16 people (81%) pleaded guilty, and 3 were convicted after a trial. The median prison term after a guilty plea was 48 months. The median after a trial was 120 months.

The trial figure is based on only 3 people. A group that small says little about trial sentences in general.

Among those who pleaded guilty, 92% had a written plea agreement, and 8% pleaded guilty with no agreement. A mandatory minimum prison term applied to 1 of the 16 people (6%).

## Where Sentences Fell Against the Guideline Range

7 sentences (44%) were within the guideline range. 4 (25%) were below the range at the government's request, and 4 (25%) were below the range without a government request. 1 (6%) was above the range.

Across all fiscal years 2016 to 2025 under this guideline, 39% of sentences were within the range. In fiscal year 2024, the figure was 54%. For everyone sentenced in federal court in fiscal year 2023 under any guideline, it was 42%.

## Supervised Release, Restitution, and Fines

14 people (88%) were ordered to serve supervised release after prison. The median term was 36 months, and 1 person (6%) received supervised release for life.

Restitution was ordered for 13 people (81%). No fine was ordered.

On criminal history, 81% were in the lowest category, Category I, and 0% were in the highest, Category VI.

## How the Year Fits Into the Yearly Table

The table lists the number of people sentenced under §2H4.1 in each fiscal year. Counts range from 7 to 16, so each year rests on a small group. Fiscal year 2025 also shows 16 people.

Fiscal year 2023 ran from October 1, 2022 to September 30, 2023\. In that year, the 81% guilty plea rate under this guideline was lower than the 97% for all guidelines combined. The all-guideline group had 64,124 people and a median prison term of 30 months.

| Fiscal year | People sentenced | Median prison | Pleaded guilty |
| ----------- | ---------------- | ------------- | -------------- |
| 2016        | 9                | 96 months     | 7 of 9         |
| 2017        | 11               | 37 months     | 91%            |
| 2018        | 8                | 30 months     | 8 of 8         |
| 2019        | 7                | 93.5 months   | 3 of 7         |
| 2020        | 8                | 114 months    | 6 of 8         |
| 2021        | 7                | 111 months    | 4 of 7         |
| 2022        | 9                | 64 months     | 8 of 9         |
| 2023        | 16               | 65 months     | 81%            |
| 2024        | 13               | 87 months     | 54%            |
| 2025        | 16               | 102 months    | 50%            |

## Limits of the Records

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 records do not describe individual cases or explain why one sentence differs from another. A year with 16 people is a small sample, and these numbers do not establish a trend.

### How We Counted

Everyone sentenced in federal court in fiscal year 2023 whose primary sentencing guideline was §2H4.1 (16), 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](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)
- [§2H4.1 Peonage, Involuntary Servitude, and Slave Trade: Federal Sentences, FY2016–2025](https://www.bodiesburied.com/trends/federal-guideline-2h4-1-peonage-involuntary-servitude-and-slave-trade/) (overview)
- [§2H4.1 Peonage, Involuntary Servitude, and Slave Trade: Federal Sentences, Fiscal Year 2024](https://www.bodiesburied.com/trends/federal-guideline-2h4-1-peonage-involuntary-servitude-and-slave-trade-fy2024/) (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.