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18 U.S.C. 1204, International parental kidnapping: How Federal Cases Ended, FY2016–2025

Dismissal was the most common way a federal case under 18 U.S.C. 1204 ended in fiscal years 2016 to 2025: 33 of 69 defendants (48%). Another 31 (45%) pleaded guilty, and 5 went to trial, none ending in an acquittal. Of the 36 convicted, 31 received a prison term on this charge, with a median of 19 m

Understanding Trends in Military Practice · 6 min read

Trends › Federal Prosecution Analysis › 18 U.S.C. 1204

In brief: Dismissal was the most common way a federal case under 18 U.S.C. 1204 ended in fiscal years 2016 to 2025: 33 of 69 defendants (48%). Another 31 (45%) pleaded guilty, and 5 went to trial, none ending in an acquittal. Of the 36 convicted, 31 received a prison term on this charge, with a median of 19 months.

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 69 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 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.

More Dismissals Than Guilty Pleas

This section of the U.S. Code carries the heading "International parental kidnapping". The post uses that heading and nothing more to identify it.

Under this section, 33 defendants (48%) had their cases dismissed and 31 (45%) pleaded guilty. Dismissals were more common than guilty pleas over the period as a whole.

The term needs care. A dismissal here means the charges were dismissed, and that includes dismissals on the government's motion, for example after a defendant pleaded guilty in another case. The records do not show which kind each dismissal was.

Trials, Convictions, and Prison

Only 5 defendants (7%) went to trial: 4 before a jury and 1 before a judge alone. None of the 5 trials ended in an acquittal.

In total, 36 of the 69 (52%) were convicted, by plea or at trial. Of those 36, 31 (86%) received a prison term on this charge. The median term, among terms of 1 month or more, was 19 months. That is the middle term when they are listed in order.

All 69 cases were felonies at the end of the case. No misdemeanor or petty offense appears for this section.

Counsel Groups Are Small

Private (retained) counsel represented 18 defendants (26%). Federal public or community defenders represented 16 (23%). CJA panel attorneys, private lawyers appointed by the court, represented 7 (10%), and 2 defendants (3%) were self-represented.

Guilty pleas ended 81% of federal defender cases and 72% of retained counsel cases. Retained counsel cases were dismissed 17% of the time, and federal defender cases 6%. Both self-represented defendants had their cases dismissed.

With groups this small, a single case changes the percentages. The numbers describe groups of cases, not the quality of lawyers. Counsel type is recorded at the end of the case, and people who hire a lawyer and people who are appointed one face different charges and circumstances.

Type of counsel at the end of the caseDefendantsPleaded guiltyDismissedTrialsAcquitted at trial
Federal public or community defender1681%6%20 (0 of 2)
CJA panel attorney75 of 71 of 710 (0 of 1)
Private (retained) counsel1872%17%20 (0 of 2)
Self-represented20 of 22 of 200

Each Fiscal Year on Its Own

Fiscal year 2017 had the most cases end, with 15, and 53% of them were dismissed. All 4 cases that ended in fiscal year 2016 were dismissed. Fiscal year 2018 had 11 cases end, and 64% of those ended in a guilty plea.

These yearly totals are too small to show a trend. The table records each year as it was.

Fiscal yearCases endedPleaded guiltyDismissedTrialsAcquitted at trial
201640 of 44 of 400
20171533%53%20 (0 of 2)
20181164%27%10 (0 of 1)
201952 of 53 of 500
202032 of 31 of 300
202162 of 64 of 600
202263 of 63 of 600
202353 of 52 of 500
202484 of 83 of 810 (0 of 1)
202563 of 62 of 610 (0 of 1)

Limits of the Count

The Federal Judicial Center counts each defendant once, by the most serious charge at the end of the case, and includes dismissed and acquitted defendants. The approved crosswalk lists no close court-martial counterpart, so only federal numbers appear here.

The records do not show the facts of any case or why prosecutors dismissed charges. They also do not show what became of a defendant after a dismissal.

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. 1204, any subsection (69), 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.

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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