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# 18 U.S.C. 1015, Naturalization, citizenship or alien registry: How Federal Cases Ended, FY2016–2025
- URL: https://www.bodiesburied.com/trends/federal-statute-18-usc-1015-case-outcomes/
- Published: 2026-11-03T06:56:03.000Z
- Updated: 2026-11-03T06:56:03.000Z
- Description: In fiscal years 2016 to 2025, 140 federal defendants had a case end with 18 U.S.C. 1015 as the most serious charge, and 33 of them (24%) had their cases dismissed. Another 105 (75%) pleaded guilty. Just 2 cases went to trial, and both ended in an acquittal.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Federal

[Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › 18 U.S.C. 1015

**In brief:** In fiscal years 2016 to 2025, 140 federal defendants had a case end with 18 U.S.C. 1015 as the most serious charge, and 33 of them (24%) had their cases dismissed. Another 105 (75%) pleaded guilty. Just 2 cases went to trial, and both ended in an acquittal.

Updated November 3, 2026 · Sources: U.S. Sentencing Commission and Federal Judicial Center, fiscal years 2016–2025

This post uses the Federal Judicial Center's records of 140 federal defendants whose cases ended in fiscal years 2016 to 2025\. The series also draws on the U.S. Sentencing Commission's records of 659,036 people sentenced 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/).

## A Dismissal Rate of 24%

Dismissals ended 33 of the 140 cases, or 24%. Guilty pleas accounted for 105 (75%), and trials for 2 (1%).

In these records, a dismissal means the charges were dismissed. That can include a dismissal on the government's motion, for example after the defendant pleaded guilty in a different case. The data does not say which reason applied in any given case.

## How the Section Is Titled

The official heading of this section reads "Naturalization, citizenship or alien registry". This post identifies the statute by that heading only.

Each defendant counted here faced the charge as a felony. The records list 140 felonies (100%) and no Class A misdemeanors or petty offenses.

The Federal Judicial Center counts every defendant whose case ended. That total includes dismissals and acquittals, so it is broader than a count of sentenced defendants.

## Dismissals Varied Widely by Year

The share of dismissed cases moved a great deal across the period. In fiscal year 2016, all 18 cases ended in a guilty plea. In fiscal year 2021, 57% were dismissed, and in fiscal year 2022 the dismissal rate was 53%.

The last years had few cases. Fiscal year 2024 had 7, with 1 of 7 dismissed. Fiscal year 2025 had 3, and all 3 were dismissed. Yearly counts this small cannot show a trend, and the records do not explain the changes.

| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| ----------- | ----------- | -------------- | --------- | ------ | ------------------ |
| 2016        | 18          | 100%           | 0%        | 0      | 0                  |
| 2017        | 13          | 85%            | 15%       | 0      | 0                  |
| 2018        | 26          | 88%            | 4%        | 2      | 2 (2 of 2)         |
| 2019        | 18          | 78%            | 22%       | 0      | 0                  |
| 2020        | 13          | 85%            | 15%       | 0      | 0                  |
| 2021        | 14          | 43%            | 57%       | 0      | 0                  |
| 2022        | 17          | 47%            | 53%       | 0      | 0                  |
| 2023        | 11          | 73%            | 27%       | 0      | 0                  |
| 2024        | 7           | 6 of 7         | 1 of 7    | 0      | 0                  |
| 2025        | 3           | 0 of 3         | 3 of 3    | 0      | 0                  |

## Did Either Trial End in a Conviction?

Both trials took place in fiscal year 2018\. The records list 1 jury trial and 1 bench trial, which is decided by a judge without a jury. Each ended in an acquittal, so no trial under this section produced a conviction.

An acquittal rate based on 2 trials says very little. It records what happened in those 2 cases and cannot be read as a measure of how other trials under this section would end.

## Convictions and Prison Terms

Every conviction under this section came from a guilty plea. That gives 105 convicted defendants, 75% of the total.

Of those 105, 72 (69%) received a prison term on this charge. For defendants with a term of 1 month or more, the median prison term was 6 months. The median is the middle term in the group. It reflects only the sentence on this charge.

## Type of Counsel at the End of the Case

A federal public or community defender represented 69 defendants (49%). Private (retained) counsel represented 37 (26%). CJA panel attorneys, who are private lawyers appointed by the court, represented 29 (21%).

Retained counsel had a higher guilty plea rate, 92%, and a lower dismissal rate, 8%. Cases with a CJA panel attorney were dismissed 31% of the time, and those with a federal defender 23% of the time. Each appointed group had 1 trial, and each of those trials ended in an acquittal.

These figures describe groups of cases, not the quality of lawyers. Type of counsel is recorded when the case ends, and defendants with hired and appointed lawyers face different charges and circumstances.

| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| -------------------------------------- | ---------- | -------------- | --------- | ------ | ------------------ |
| Federal public or community defender   | 69         | 75%            | 23%       | 1      | 1 (1 of 1)         |
| CJA panel attorney                     | 29         | 66%            | 31%       | 1      | 1 (1 of 1)         |
| Private (retained) counsel             | 37         | 92%            | 8%        | 0      | 0                  |

## What the Counts Leave Out

No close court-martial counterpart for this statute appears in the approved crosswalk, so only federal numbers are reported. The records do not describe the facts of any case, the evidence, or the reasons behind a dismissal or a verdict.

### How We Counted

Every federal defendant whose case ended in fiscal years 2016 to 2025 and whose most serious charge at the end of the case (TTITLE1) was under 18 U.S.C. 1015, any subsection (140), Federal Judicial Center, counted as in the federal courts' Table D-4\. Type of counsel is TCOUNSEL; labels from the FJC criminal codebook. Section heading from the U.S. Code as published by the Office of the Law Revision Counsel (release point 119-136).

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.

**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.

**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.

**Type of counsel describes groups of cases, not lawyers.** The Federal Judicial Center records the type of counsel at the end of the case. Defendants who hire a lawyer differ from defendants who receive an appointed lawyer in their charges, criminal history, and circumstances, and some defendants change lawyers during a case. Differences in outcomes by type of counsel therefore cannot be credited to the type of lawyer.

## 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)
- [18 U.S.C. 1001, Statements or entries generally: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1001-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 1014, Loan and credit applications generally; renewals and discounts; crop insurance: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1014-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 1029, Fraud and related activity in connection with access devices: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1029-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 1030, Fraud and related activity in connection with computers: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1030-case-outcomes/) (same title of the U.S. Code)
- [Appointed vs. Retained Lawyers in Federal Criminal Cases: How Cases Ended, 2016–2025](https://www.bodiesburied.com/trends/federal-appointed-vs-retained-counsel-outcomes/)
- [Are Courts-Martial More Likely to End in Acquittal Than Federal Trials?](https://www.bodiesburied.com/trends/federal-trial-acquittal-rates-vs-courts-martial/)
- [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.