§2L2.2 Fraudulently Acquiring Documents Relating to Naturalization, Citizenship, or Legal Resident Status for Own Use: Federal Sentences, Fiscal Year 2025
In fiscal year 2025, 468 of the 529 people sentenced under §2L2.2 (88%) received a sentence within the guideline range, compared with 75% the year before and 51% for all federal cases. The median prison term was 3.3 months, and 99% pleaded guilty.
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Trends › Federal Prosecution Analysis › §2L2.2 Fraudulently Acquiring Documents Relating to Naturali › §2L2.2: FY2025
In brief: In fiscal year 2025, 468 of the 529 people sentenced under §2L2.2 (88%) received a sentence within the guideline range, compared with 75% the year before and 51% for all federal cases. The median prison term was 3.3 months, and 99% pleaded guilty.
This post uses the U.S. Sentencing Commission's records of 529 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.
Within-Range Sentences Were Higher Than the Year Before
Every one of the 529 people had guideline range information recorded. 468 (88%) were sentenced within the range. 35 (7%) were above it. 16 (3%) were below it without a government request, and 10 (2%) were below it at the government's request.
In fiscal year 2024, 75% of people under this guideline were within the range. Across all federal cases in fiscal year 2025, 51% were. The records do not explain the change from 2024, and one year is not a trend.
Who Went to Prison
490 of the 529 people (93%) received a prison term. 35 (7%) received probation only, with no prison or other confinement.
The median prison term was 3.3 months. A quarter of the people sent to prison received 6 months or more, and a quarter received 1.9 months or less. For all 66,662 people sentenced in federal court that year, the median prison term was 24 months. That group covers every offense type, and none of these figures measures time served.
Guilty Pleas, Trials, and Agreements
522 people (99%) pleaded guilty. 7 were convicted after a trial. For federal court as a whole, the guilty plea share was 98%.
The median prison term was 3.1 months after a guilty plea and 18 months after a trial. Only 7 people make up the trial figure. Among guilty pleas, 31% included a written agreement and 69% were straight pleas.
Mandatory Minimums, Supervised Release, and Money Penalties
A mandatory minimum prison term applied to 23 of the 528 people with that information recorded (4%).
341 people (64%) were ordered to serve supervised release after prison, and the median term was 36 months. 13 (2%) were fined. 5 (less than 1%) were ordered to pay restitution.
Where This Guideline Fits
The manual title of §2L2.2 is "Fraudulently Acquiring Documents Relating to Naturalization, Citizenship, or Legal Resident Status for Own Use; False Personation or Fraudulent Marriage by Alien to Evade Immigration Law; Fraudulently Acquiring or Improperly Using a United States Passport." The U.S. Sentencing Commission puts these cases in the Immigration offense type. The fiscal year ran from October 1, 2024 to September 30, 2025.
84% of the people were in criminal history category I, and less than 1% were in category VI. Court-martial records do not track criminal history, and the approved crosswalk gives this guideline no close court-martial counterpart. This post reports federal numbers alone.
The Last Year of the Table
Fiscal year 2025 is the final year in the data. In the previous year, 394 people were sentenced under §2L2.2, with a median prison term of 4.2 months.
For fiscal years 2016 to 2025 combined, 6,602 people were sentenced. 87% went to prison, the median prison term was 3.9 months, 98% pleaded guilty, and 76% were within the range. The table shows every year. People who were acquitted or whose cases were dismissed do not appear in these records.
| Fiscal year | People sentenced | Median prison | Pleaded guilty |
|---|---|---|---|
| 2016 | 769 | 4 months | 98% |
| 2017 | 691 | 4.4 months | 98% |
| 2018 | 935 | 4 months | 98% |
| 2019 | 962 | 3.5 months | 99% |
| 2020 | 642 | 3.4 months | 98% |
| 2021 | 582 | 3.5 months | more than 99% |
| 2022 | 661 | 3.3 months | 98% |
| 2023 | 437 | 4.2 months | 97% |
| 2024 | 394 | 4.2 months | 98% |
| 2025 | 529 | 3.3 months | 99% |
How We Counted
Everyone sentenced in federal court in fiscal year 2025 whose primary sentencing guideline was §2L2.2 (529), 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)
- §2L2.2 Fraudulently Acquiring Documents Relating to Naturalization, Citizenship, or Legal Resident Status for Own Use: Federal Sentences, FY2016–2025 (overview)
- §2L2.2 Fraudulently Acquiring Documents Relating to Naturalization, Citizenship, or Legal Resident Status for Own Use: 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.