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# §2L2.1 Trafficking in a Document Relating to Naturalization, Citizenship, or Legal Resident Status, or a United States Passport: Federal Sentences, Fiscal Year 2021
- URL: https://www.bodiesburied.com/trends/federal-guideline-2l2-1-trafficking-in-a-document-relating-to-naturalization-fy2021/
- Published: 2026-11-04T10:26:26.000Z
- Updated: 2026-11-04T10:26:25.000Z
- Description: All 57 people sentenced in fiscal year 2021 under §2L2.1 pleaded guilty, so none was convicted after a trial. Of the 57, 38 (67%) received a prison term, with a median of 12 months. Sentences within the guideline range were 39% of the total.
- 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: FY2021

**In brief:** All 57 people sentenced in fiscal year 2021 under §2L2.1 pleaded guilty, so none was convicted after a trial. Of the 57, 38 (67%) received a prison term, with a median of 12 months. Sentences within the guideline range were 39% of the total.

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 57 people sentenced in federal court in fiscal year 2021\. 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/).

## Every Case Ended in a Guilty Plea

The U.S. Sentencing Commission recorded 57 of 57 people (100%) as pleading guilty in fiscal year 2021, and 0 as convicted after a trial. Because no one was convicted at trial, the records have no trial prison term to report.

Across all guidelines in that year, 98% of 57,287 people pleaded guilty. A written plea agreement was part of 89% of the guilty pleas under §2L2.1, and 11% were straight pleas with no agreement.

The count of 57 is small, and the year should not be read as a trend.

## Prison Terms and Probation

Of the 57 people, 38 (67%) were sent to prison. Probation only, with no prison or other confinement, went to 12 (21%).

Among those sent to prison, the median prison term was 12 months. A quarter received 23.2 months or more, and a quarter received 4.8 months or less. Prison terms here are the sentences imposed and not the time served.

The all-guidelines median that year was 29 months. That figure covers every offense type, so it is context and not a direct comparison.

## Within the Range, Below It, and Above It

Within the range: 39% (22 people). Below the range at the government's request: 32% (18). Below the range without a government request: 26% (15). Above the range: 4% (2).

Across all guidelines in fiscal year 2021, 43% of sentences were within the range. For §2L2.1 across fiscal years 2016 to 2025, the figure was 45%. The year before, fiscal year 2020, was 39%, and the following year, 2022, was 26%.

No one among the 56 people with mandatory minimum information recorded had a mandatory minimum prison term.

## Supervised Release, Fines, and Restitution

Supervised release after prison was ordered for 32 people (56%), and the median term was 24 months. A fine was ordered for 10 (18%). Restitution was ordered for 1 person (2%).

For criminal history, 84% were in category I and 4% were in category VI. Court-martial records have no such field.

## How the Guideline Is Named and Counted

In the Sentencing Guidelines Manual, §2L2.1 carries the title "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."

All 57 people fell into the Immigration offense type. Only convicted and sentenced people appear, so acquittals and dismissals are missing. Fiscal year 2021 ran from October 1, 2020 to September 30, 2021.

## Years Before and After, and What Is Not Known

In fiscal year 2020, 71 people were sentenced under this guideline, with a median prison term of 12 months. In fiscal year 2022, 84 people were sentenced, with a median of 10 months. The table lists all years from 2016 to 2025.

The records do not give case facts or sentencing reasons. There is no close court-martial counterpart for this guideline in the approved crosswalk, so this post reports the federal numbers on their own.

| 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 2021 whose primary sentencing guideline was §2L2.1 (57), 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)
- [§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 2020](https://www.bodiesburied.com/trends/federal-guideline-2l2-1-trafficking-in-a-document-relating-to-naturalization-fy2020/) (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 2022](https://www.bodiesburied.com/trends/federal-guideline-2l2-1-trafficking-in-a-document-relating-to-naturalization-fy2022/) (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.