Guilty Pleas in Kidnapping Cases: Federal Court vs. Courts-Martial
Guilty pleas were far more common in federal kidnapping cases than in courts-martial. In federal court, 83% of the 1,075 people sentenced under guideline §2A4.1 pleaded guilty, and 69% of 944 defendants charged under 18 U.S.C. 1201 pleaded guilty. In courts-martial charging kidnapping, 8 of 24 cases
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In brief: Guilty pleas were far more common in federal kidnapping cases than in courts-martial. In federal court, 83% of the 1,075 people sentenced under guideline §2A4.1 pleaded guilty, and 69% of 944 defendants charged under 18 U.S.C. 1201 pleaded guilty. In courts-martial charging kidnapping, 8 of 24 cases with a plea recorded (33%) were guilty pleas.
This post uses the U.S. Sentencing Commission's records of 1,075 people sentenced in federal court in fiscal years 2016 to 2025 and the Federal Judicial Center's records of 944 federal defendants whose cases ended in fiscal years 2016 to 2025, compared with court-martial results from this site's Military Trial Results data (updated November 2, 2026). 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.
Pleas in Court-Martial Kidnapping Cases
The court-martial records list 24 cases charging kidnapping, now Article 125, that have a plea recorded. The trial dates run from 2016 to 2025. Of the 24, 8 (33%) were guilty pleas, 3 (13%) were mixed pleas, and 13 (54%) were not-guilty pleas.
A mixed plea is a guilty plea to some charges and not guilty to others. Together, mixed and not-guilty pleas make these contested cases, and they were the larger group.
No other kidnapping cases in the records lack a plea entry. Among 6 guilty pleas where the records show whether there was a plea agreement, all 6 had one.
Pleas Among Federal Defendants
Federal data here comes from 2 sources. The U.S. Sentencing Commission covers people who were convicted and sentenced. Of 1,075 people sentenced under guideline §2A4.1, which covers kidnapping, abduction, and unlawful restraint, 896 (83%) pleaded guilty and 179 were convicted at trial. Among those guilty pleas, 91% had a written plea agreement and 9% were straight pleas with no agreement.
The Federal Judicial Center covers every defendant whose case ended, including dismissals and acquittals. It counted 944 defendants charged under 18 U.S.C. 1201 in fiscal years 2016 to 2025. Of these, 652 (69%) pleaded guilty, 101 (11%) had their cases dismissed, and 191 (20%) went to trial.
The second figure is lower, and dismissals and acquittals stay in that count. A plea rate among people convicted and a plea rate among all defendants are different measures.
What Happened at Trial
Of the 191 federal trials, 25 ended in an acquittal (13%). Jury trials numbered 185, with 21 acquittals. Bench trials numbered 6, with 4 acquittals.
Altogether, 818 of the 944 defendants (87%) were convicted, by plea or at trial. The court-martial records in this comparison count pleas, not verdicts, so they do not give a comparable conviction rate.
Pleas by Service
The Army had 13 cases with a plea recorded, and 3 were guilty pleas (23%). The Air Force had 2 cases, and both were guilty pleas. The Navy had 5 cases, and 1 was a guilty plea. The Marine Corps had 4 cases, and 2 were guilty pleas.
Air Force plea information is missing for most trials before 2020, so the Air Force count is especially incomplete. Plea agreement records come mostly from the Army, Navy, and Marine Corps. Every service count except the Army's is under 10 cases.
| Service | Cases with a plea recorded | Guilty pleas | Share |
|---|---|---|---|
| Army | 13 | 3 | 23% |
| Air Force | 2 | 2 | 2 of 2 |
| Navy | 5 | 1 | 1 of 5 |
| Marine Corps | 4 | 2 | 2 of 4 |
Pleas by Year
The yearly table shows no court-martial cases with a plea recorded from 2016 to 2020. In 2021, 4 of 6 cases were guilty pleas. In 2022, it was 1 of 4. In 2023, it was 2 of 6, in 2024 it was 1 of 7, and in 2025 it was 0 of 1.
The federal plea rate among defendants whose cases ended ranged from 69% in 2020 to 90% in 2021 over the same fiscal years. Each court-martial year holds too few cases to describe a direction.
| Year | Courts-martial: guilty pleas | Federal: pleaded guilty |
|---|---|---|
| 2016 | 0 of 0 (none) | 85% |
| 2017 | 0 of 0 (none) | 83% |
| 2018 | 0 of 0 (none) | 86% |
| 2019 | 0 of 0 (none) | 87% |
| 2020 | 0 of 0 (none) | 69% |
| 2021 | 4 of 6 (4 of 6) | 90% |
| 2022 | 1 of 4 (1 of 4) | 88% |
| 2023 | 2 of 6 (2 of 6) | 82% |
| 2024 | 1 of 7 (1 of 7) | 82% |
| 2025 | 0 of 1 (0 of 1) | 79% |
What the Records Cannot Show
The records cannot show why a federal defendant or an accused service member chose a plea. They cannot show how many plea offers were made, or what the terms were.
The counts also differ in time. Federal years run from October 1 to the end of September, and court-martial years follow the trial date. A court-martial has no grand jury, while a federal felony needs an indictment, so the cases that reach each system are not selected the same way.
How We Counted
Courts-martial: every court-martial charging kidnapping (Article 125 since 2019) with a trial date in 2016 to 2025 and a plea recorded (24). Federal: people sentenced under guideline §2A4.1 (kidnapping, abduction, unlawful restraint) (1,075, U.S. Sentencing Commission) and defendants charged under 18 U.S.C. 1201 whose cases ended (944, Federal Judicial Center), fiscal years 2016 to 2025.
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
Who is in each set of numbers. The federal sentencing numbers come from the U.S. Sentencing Commission. They count only people who were convicted and sentenced in federal district court. People whose cases were dismissed or who were acquitted are not in them. The military numbers come from court-martial results, which include acquittals. To compare acquittal or dismissal rates, the federal side uses a different source: the Federal Judicial Center's case data, which counts every defendant whose case ended.
Different cases reach each system. Federal prosecutors bring a narrow set of cases. In fiscal year 2024, immigration and drug trafficking cases were 59% of everyone sentenced in federal court (36,664 of 61,678). Many crimes that the military prosecutes, such as most assaults, most sexual assaults between adults, and drug use, are usually state crimes for civilians and reach federal court only in special situations, such as on federal land or in Indian Country. A federal case and a court-martial for the same crime can involve different kinds of facts.
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.
Offense categories do not line up exactly. Each comparison uses a federal offense group chosen to match the military article as closely as possible (see the crosswalk). Some matches are close; others are partial. The post says which federal guideline or statute was used and why it is not an exact match.
Plea agreements work differently. In federal court, most plea agreements do not bind the judge on the sentence. Since 2019, a military plea agreement can set a minimum and maximum sentence that the military judge must follow if the judge accepts the agreement. The federal numbers count anyone who pleaded guilty, with or without a written agreement.
How "plea" and "trial" are counted. In the federal sentencing numbers, "trial" means the person was convicted after a trial, including people who pleaded guilty to some counts and went to trial on others. People acquitted at trial are not in these numbers at all (see "Who is in each set of numbers"). In the federal case data, the trial rate counts both convictions and acquittals at trial among all defendants whose cases ended, including dismissed cases. Military numbers count contested cases that reached a verdict. These denominators are not the same, and each post states the one it uses.
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)
- Robbery and Kidnapping: Federal vs. Court-Martial Sentences, 2016–2025 (overview)
- Kidnapping Charges: Federal Trial Acquittals vs. Contested Army Courts-Martial
- Kidnapping Charges: How Often Federal Trials and Courts-Martial End in Acquittal
- Kidnapping Convictions of Junior Enlisted (E-1 to E-4): Courts-Martial Compared With Federal Court
- Kidnapping: Federal Sentences vs. Army Courts-Martial
- Is Army Kidnapping Prosecution Rising or Falling? Article 125, 2021–2025 (court-martial data)
- Article 125 UCMJ: Kidnapping (law firm reference page)
- 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.