> ## 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. # §2L2.1 Trafficking in a Document Relating to Naturalization, Citizenship, or Legal Resident Status, or a United States Passport: Federal Sentences, Fiscal Year 2019 - URL: https://www.bodiesburied.com/trends/federal-guideline-2l2-1-trafficking-in-a-document-relating-to-naturalization-fy2019/ - Published: 2026-11-04T10:26:24.000Z - Updated: 2026-11-04T10:26:24.000Z - Description: In fiscal year 2019, 78 of 104 people sentenced under §2L2.1 (75%) received a prison term. The median prison term was 10 months. A mandatory minimum applied to 12 people (12%). - Author: Jocelyn C. Stewart - Tags: Understanding Trends, Federal [Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › [§2L2.1 Trafficking in a Document Relating to Naturalization,](https://www.bodiesburied.com/trends/federal-guideline-2l2-1-trafficking-in-a-document-relating-to-naturalization/) › §2L2.1: FY2019 **In brief:** In fiscal year 2019, 78 of 104 people sentenced under §2L2.1 (75%) received a prison term. The median prison term was 10 months. A mandatory minimum applied to 12 people (12%). 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 104 people sentenced in federal court in fiscal year 2019\. 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/). ## How Often a Mandatory Minimum Applied A mandatory minimum prison term applied to 12 of the 104 people sentenced (12%). Mandatory minimums come from the statute for the offense and not from the guideline. The records show how often one applied, not which offense produced it. Among the 78 people sent to prison, the median prison term was 10 months. A quarter received 23.2 months or more, and a quarter received 6 months or less. ## Prison, Probation, and Supervised Release Of the 104 people, 78 (75%) received prison and 19 (18%) received probation only, with no prison or other confinement. Across fiscal years 2016 to 2025 under this guideline, 70% went to prison. Supervised release was ordered for 62 people (60%), with a median term of 36 months. A fine was ordered for 16 (15%), and restitution for 2 (2%). The prison terms are those imposed by the court. They are not the time served. ## Trials Led to a Longer Median in 2019 A total of 97 of 104 people (93%) pleaded guilty, and 7 were convicted after a trial. Of the guilty pleas, 85% had a written plea agreement and 15% did not. The median prison term was 10 months after a guilty plea and 36 months after a trial. The trial median is based on 4 people sent to prison, so it describes a very small group. ## Comparison With the Guideline Range Within the range: 49% (51 people). Below the range at the government's request: 29% (30). Below the range without a government request: 21% (22). Above the range: less than 1% (1). For all guidelines in fiscal year 2019, 51% of 76,538 people received a within-range sentence. The §2L2.1 figure over fiscal years 2016 to 2025 was 45%. The fiscal year 2018 figure was 48% and the fiscal year 2020 figure was 39%. ## Naming the Guideline and Setting the Scope Under the Guidelines Manual, §2L2.1 is titled "Trafficking in a Document Relating to Naturalization, Citizenship, or Legal Resident Status, or a United States Passport; False Statement in Respect to the Citizenship or Immigration Status of Another; Fraudulent Marriage to Assist Alien to Evade Immigration Law." The Commission placed all 104 cases in its Immigration offense type. Only convicted and sentenced people are counted. Fiscal year 2019 ran from October 1, 2018 to September 30, 2019\. In that year, the median prison term across all guidelines was 21 months. ## Criminal History and Gaps in the Records By criminal history category, 85% were in category I and 2% in category VI. Court-martial files have no equivalent field. The records do not show case facts or why a sentence was chosen. 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 yearly table shows the other fiscal years. | Fiscal year | People sentenced | Median prison | Pleaded guilty | | ----------- | ---------------- | ------------- | -------------- | | 2016 | 130 | 9.7 months | 95% | | 2017 | 153 | 12 months | 95% | | 2018 | 117 | 10 months | 97% | | 2019 | 104 | 10 months | 93% | | 2020 | 71 | 12 months | 90% | | 2021 | 57 | 12 months | 100% | | 2022 | 84 | 10 months | 94% | | 2023 | 69 | 10 months | 97% | | 2024 | 47 | 13.5 months | 89% | | 2025 | 53 | 5.4 months | 100% | ### How We Counted Everyone sentenced in federal court in fiscal year 2019 whose primary sentencing guideline was §2L2.1 (104), 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) - [§2L2.1 Trafficking in a Document Relating to Naturalization, Citizenship, or Legal Resident Status, or a United States Passport: Federal Sentences, FY2016–2025](https://www.bodiesburied.com/trends/federal-guideline-2l2-1-trafficking-in-a-document-relating-to-naturalization/) (overview) - [§2L2.1 Trafficking in a Document Relating to Naturalization, Citizenship, or Legal Resident Status, or a United States Passport: Federal Sentences, Fiscal Year 2018](https://www.bodiesburied.com/trends/federal-guideline-2l2-1-trafficking-in-a-document-relating-to-naturalization-fy2018/) (previous or next fiscal year) - [§2L2.1 Trafficking in a Document Relating to Naturalization, Citizenship, or Legal Resident Status, or a United States Passport: Federal Sentences, Fiscal Year 2020](https://www.bodiesburied.com/trends/federal-guideline-2l2-1-trafficking-in-a-document-relating-to-naturalization-fy2020/) (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.