§2H4.1 Peonage, Involuntary Servitude, and Slave Trade: Federal Sentences, Fiscal Year 2024
In fiscal year 2024, 7 of the 13 people sentenced under guideline §2H4.1, "Peonage, Involuntary Servitude, and Slave Trade," pleaded guilty (54%), and 6 were convicted after a trial. That is a lower plea rate than the 71% for all fiscal years 2016 to 2025. The median prison term was 87 months, and 1
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Trends › Federal Prosecution Analysis › §2H4.1 Peonage, Involuntary Servitude, and Slave Trade › §2H4.1: FY2024
In brief: In fiscal year 2024, 7 of the 13 people sentenced under guideline §2H4.1, "Peonage, Involuntary Servitude, and Slave Trade," pleaded guilty (54%), and 6 were convicted after a trial. That is a lower plea rate than the 71% for all fiscal years 2016 to 2025. The median prison term was 87 months, and 12 of the 13 people received prison.
This post uses the U.S. Sentencing Commission's records of 13 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 Year With Nearly Even Pleas and Trials
The U.S. Sentencing Commission counted 13 people in fiscal year 2024 whose primary guideline was §2H4.1. 7 (54%) pleaded guilty, and 6 were convicted at trial.
Guilty pleas were less common here than across all guidelines in fiscal year 2024, where 97% of the 61,678 people sentenced pleaded guilty. Every person who pleaded guilty under §2H4.1 had a written plea agreement, which is 7 of 7.
The median prison term after a guilty plea was 70 months. After a trial, it was 90.5 months, based on the 6 people convicted at trial and sent to prison.
The Overall Prison Numbers
12 of the 13 people (92%) were sentenced to prison. 1 person (8%) received probation only. Among those sent to prison, the median term was 87 months, or 7.2 years.
A quarter received 110.2 months or more, and a quarter received 70 months or less. No mandatory minimum applied to any of the 13 people.
The Commission lists these cases under the offense type Individual Rights. Only people who were convicted and sentenced are in the data, and the terms are those imposed, not time served.
Sentences Against the Guideline Range
7 sentences (54%) were within the guideline range. 2 (15%) were below the range at the government's request, 2 (15%) were below it without a government request, and 2 (15%) were above it.
The within-range share was higher than in fiscal year 2023, when it was 44%, and higher than in fiscal year 2025, when it was 38%. It was also higher than the 39% for all years under this guideline. For everyone sentenced in fiscal year 2024 under any guideline, it was 46%.
After Prison: Supervised Release, Restitution, and Criminal History
11 people (85%) were ordered to serve supervised release, with a median term of 36 months. Restitution was ordered for 11 people (85%), and no fines were ordered.
77% were in the lowest criminal history category, Category I. 0% were in the highest, Category VI.
Neighboring Years and the Full Table
The median prison term was 65 months in fiscal year 2023 and 102 months in fiscal year 2025. The 87 months in fiscal year 2024 falls between those figures. For all years under this guideline, the median is 72 months.
The table below gives the count, median, and plea rate for each year. The groups range from 7 to 16 people. Fiscal year 2024 ran from October 1, 2023 to September 30, 2024.
| 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% |
What Cannot Be Read From This Data
There is no close court-martial counterpart for this guideline in the approved crosswalk, so this post reports the federal numbers on their own.
With 13 people, a change in a few sentences moves the percentages noticeably. The records do not show why trials were more common in this year, and one year is not a trend.
How We Counted
Everyone sentenced in federal court in fiscal year 2024 whose primary sentencing guideline was §2H4.1 (13), 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)
- §2H4.1 Peonage, Involuntary Servitude, and Slave Trade: Federal Sentences, FY2016–2025 (overview)
- §2H4.1 Peonage, Involuntary Servitude, and Slave Trade: Federal Sentences, Fiscal Year 2023 (previous or next fiscal year)
- §2H4.1 Peonage, Involuntary Servitude, and Slave Trade: Federal Sentences, Fiscal Year 2025 (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.