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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 2025

The median prison term under §2L2.1 in fiscal year 2025 was 5.4 months for the 39 of 53 people sent to prison (74%). That is the lowest yearly median in the table. All 53 people pleaded guilty, and 58% of sentences were within the guideline range.

· Understanding Trends in Military Practice · 6 min read

Trends › Federal Prosecution Analysis › §2L2.1 Trafficking in a Document Relating to Naturalization, › §2L2.1: FY2025

In brief: The median prison term under §2L2.1 in fiscal year 2025 was 5.4 months for the 39 of 53 people sent to prison (74%). That is the lowest yearly median in the table. All 53 people pleaded guilty, and 58% of sentences were within the guideline range.

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 53 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.

A Median of 5.4 Months

Among the 39 people sent to prison in fiscal year 2025, the median prison term was 5.4 months. A quarter received 14.5 months or more, and a quarter received 0.1 months or less.

The median in fiscal year 2024 was 13.5 months, and the median across fiscal years 2016 to 2025 was 11 months. For all guidelines in fiscal year 2025, it was 24 months, though that figure covers every offense type.

With 53 people in the group, this is a small year, and the records do not show why the median was low. Terms are those imposed, not time served.

All 53 People Pleaded Guilty

The records list 53 of 53 people (100%) as pleading guilty and 0 as convicted after a trial. There is no trial prison term to report.

A written plea agreement was part of 85% of the guilty pleas, and 15% were straight pleas with no agreement. Across all guidelines in fiscal year 2025, 98% of 66,662 people pleaded guilty.

Most Sentences Were Within the Range

Within the range: 58% (31 people). Below the range at the government's request: 15% (8). Below the range without a government request: 25% (13). Above the range: 2% (1).

All guidelines combined had 51% within the range in fiscal year 2025. The §2L2.1 figure was 34% in fiscal year 2024 and 45% across fiscal years 2016 to 2025. Fiscal year 2025 ran from October 1, 2024 to September 30, 2025.

Probation, Supervised Release, and Other Orders

Besides the 39 people sent to prison, 10 (19%) received probation only, with no prison or other confinement.

Supervised release was ordered for 30 people (57%), with a median term of 29.5 months. A fine was ordered for 10 (19%) and restitution for 2 (4%). A mandatory minimum prison term applied to 2 of the 53 people (4%).

In terms of criminal history, 89% were in category I and 0% in category VI. Court-martial files have no criminal history field.

Guideline Title and Data 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 classed all 53 cases as Immigration. The data include only people who were convicted and sentenced.

Limits of This Year's Numbers

Fiscal year 2025 is the last year in the yearly table, which begins in 2016. The table shows every year's count, median, and plea share.

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 yearPeople sentencedMedian prisonPleaded guilty
20161309.7 months95%
201715312 months95%
201811710 months97%
201910410 months93%
20207112 months90%
20215712 months100%
20228410 months94%
20236910 months97%
20244713.5 months89%
2025535.4 months100%

How We Counted

Everyone sentenced in federal court in fiscal year 2025 whose primary sentencing guideline was §2L2.1 (53), 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.

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.

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