§2H4.1 Peonage, Involuntary Servitude, and Slave Trade: Federal Sentences, Fiscal Year 2025
In fiscal year 2025, 16 people were sentenced under guideline §2H4.1, "Peonage, Involuntary Servitude, and Slave Trade." 13 of them (81%) received a prison term, and 3 (19%) received probation only. The median prison term was 102 months, the highest median in the yearly table apart from 114 months i
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Trends › Federal Prosecution Analysis › §2H4.1 Peonage, Involuntary Servitude, and Slave Trade › §2H4.1: FY2025
In brief: In fiscal year 2025, 16 people were sentenced under guideline §2H4.1, "Peonage, Involuntary Servitude, and Slave Trade." 13 of them (81%) received a prison term, and 3 (19%) received probation only. The median prison term was 102 months, the highest median in the yearly table apart from 114 months in fiscal year 2020 and 111 months in fiscal year 2021.
This post uses the U.S. Sentencing Commission's records of 16 people sentenced in federal court in fiscal year 2025. 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.
Prison, Probation, and One Life Sentence
The U.S. Sentencing Commission counted 16 people in fiscal year 2025 whose primary guideline was §2H4.1. 13 (81%) were sentenced to prison, and 3 (19%) received probation only, with no prison or other confinement.
Among those sent to prison, the median term was 102 months, which is 8.5 years. A quarter received 135 months or more, and a quarter received 60 months or less. 1 person received a life sentence.
A mandatory minimum prison term applied to 2 of the 16 people (13%).
Pleas and Trials Split Evenly
8 of the 16 people (50%) pleaded guilty, and 8 were convicted after a trial. This is the lowest plea rate in the yearly table. All 8 who pleaded guilty had a written plea agreement.
The median prison term after a guilty plea was 240.5 months. After a trial it was 60 months, based on 7 people sent to prison.
Groups of 7 and 8 people are small, so these medians should be read with caution. The records do not show which sentence belongs to which case.
Position Against the Guideline Range
6 sentences (38%) were within the guideline range. 4 (25%) were below the range at the government's request, and 6 (38%) were below it without a government request. None were above the range.
The within-range share was lower than the 54% in fiscal year 2024 and lower than the 39% for all years under this guideline, by a small margin in the second case. For all guidelines combined in fiscal year 2025, it was 51%.
Supervised Release, Fines, and Restitution
13 people (81%) were ordered to serve supervised release after prison, with a median term of 36 months. A fine was ordered for 2 people (13%). Restitution was ordered for 12 people (75%).
On criminal history, 75% were in the lowest category, Category I, and 0% were in the highest, Category VI.
How Fiscal Year 2025 Compares With Everyone Sentenced
For every guideline in fiscal year 2025, 66,662 people were sentenced. Their median prison term was 24 months, and 98% pleaded guilty. The §2H4.1 median is higher and the plea rate is much lower.
The all-years figures for §2H4.1 cover 104 people. 91% were sent to prison, and the median prison term was 72 months. Fiscal year 2025 ran from October 1, 2024 to September 30, 2025, and the Commission files these cases under the offense type Individual Rights.
| 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 data counts only people who were convicted and sentenced. Acquittals and dismissals are not in it, and prison terms are the terms imposed, not time served. A single year of 16 people does not establish a trend.
How We Counted
Everyone sentenced in federal court in fiscal year 2025 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 (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 2024 (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.