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# 18 U.S.C. 1425, Procurement of citizenship or naturalization unlawfully: How Federal Cases Ended, FY2016–2025
- URL: https://www.bodiesburied.com/trends/federal-statute-18-usc-1425-case-outcomes/
- Published: 2026-11-03T06:55:49.000Z
- Updated: 2026-11-03T06:55:49.000Z
- Description: Under 18 U.S.C. 1425, 260 federal defendants had their cases end in fiscal years 2016 to 2025. Of those, 161 (62%) pleaded guilty, 71 (27%) had their cases dismissed, and 28 (11%) went to trial, where 2 were acquitted. The median prison term on this charge was 7.5 months, and 114 of the 187 convicte
- 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. 1425

**In brief:** Under 18 U.S.C. 1425, 260 federal defendants had their cases end in fiscal years 2016 to 2025\. Of those, 161 (62%) pleaded guilty, 71 (27%) had their cases dismissed, and 28 (11%) went to trial, where 2 were acquitted. The median prison term on this charge was 7.5 months, and 114 of the 187 convicted (61%) received a prison term.

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 260 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/).

## Felony Charges and Prison Terms

Every charge in this group was a felony: 260 (100%). No Class A misdemeanor or petty offense appears.

Of the convicted, 114 of 187 (61%) received a prison term on this charge. The median term, counting terms of 1 month or more, was 7.5 months.

The median is the middle term when the terms are ordered by length. The records do not say what other sentence, if any, the remaining convicted defendants received.

## The Section and the Count

Section 1425 of Title 18 is headed "Procurement of citizenship or naturalization unlawfully". The defendants counted here are those whose most serious charge at the end of the case fell under this section.

The Federal Judicial Center includes every defendant whose case ended. That means dismissals and acquittals are in the total, not only sentenced defendants.

## Pleas, Dismissals, and Trials

A guilty plea ended 161 cases. Another 71 ended in dismissal. In the FJC records, a dismissal includes charges dismissed on the government's motion, for example after a guilty plea in a separate case.

Of the 28 trials, juries decided 24 and acquitted in 2 (8%). Judges decided 4 bench trials and acquitted in none (0 of 4). Across all trials, the acquittal rate was 7%.

Overall, 187 of the 260 (72%) were convicted by plea or at trial.

## What Changed From Year to Year?

Yearly counts were uneven. The most cases ended in fiscal year 2017 (45), and the fewest in fiscal year 2024 (7).

Fiscal year 2025 had 34 cases, and 76% of them were dismissed. That is the highest yearly dismissal rate in the period. Fiscal year 2023 had the most trials in a single year, 7, and none ended in an acquittal.

The records do not explain these shifts, and the small yearly counts make single-year rates unstable.

| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| ----------- | ----------- | -------------- | --------- | ------ | ------------------ |
| 2016        | 35          | 49%            | 37%       | 5      | 0 (0 of 5)         |
| 2017        | 45          | 87%            | 9%        | 2      | 0 (0 of 2)         |
| 2018        | 42          | 81%            | 7%        | 5      | 2 (2 of 5)         |
| 2019        | 25          | 84%            | 12%       | 1      | 0 (0 of 1)         |
| 2020        | 13          | 62%            | 23%       | 2      | 0 (0 of 2)         |
| 2021        | 21          | 71%            | 29%       | 0      | 0                  |
| 2022        | 20          | 45%            | 35%       | 4      | 0 (0 of 4)         |
| 2023        | 18          | 28%            | 33%       | 7      | 0 (0 of 7)         |
| 2024        | 7           | 6 of 7         | 0 of 7    | 1      | 0 (0 of 1)         |
| 2025        | 34          | 21%            | 76%       | 1      | 0 (0 of 1)         |

## Type of Counsel

Private (retained) counsel represented 112 defendants (43%), and federal public or community defenders represented 84 (32%). CJA panel attorneys, who are private lawyers appointed by the court, represented 17 (7%). Only 2 defendants represented themselves.

Retained counsel had a plea rate of 81%, a dismissal rate of 9%, and 11 trials with 2 acquittals (18%). Federal defenders had a plea rate of 63%, a dismissal rate of 18%, and 16 trials with no acquittals (0%). CJA panel attorneys had a plea rate of 82% and 1 trial.

The type of counsel is recorded at the end of the case. Defendants who hire a lawyer and those who are assigned one face different charges and circumstances. These numbers describe groups of cases, not the quality of lawyers.

| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| -------------------------------------- | ---------- | -------------- | --------- | ------ | ------------------ |
| Federal public or community defender   | 84         | 63%            | 18%       | 16     | 0 (0%)             |
| CJA panel attorney                     | 17         | 82%            | 12%       | 1      | 0 (0 of 1)         |
| Private (retained) counsel             | 112        | 81%            | 9%        | 11     | 2 (18%)            |
| Self-represented                       | 2          | 2 of 2         | 0 of 2    | 0      | 0                  |

## Limits of the Data

The records count the most serious charge at the end of each case and nothing about the facts behind it. They cannot show the evidence, the reasons for a dismissal, or why a defendant chose trial.

The approved crosswalk has no close court-martial counterpart for this section, so only federal numbers are reported.

### 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. 1425, any subsection (260), 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. 1361, Government property or contracts: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1361-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 1382, Entering military, naval, or Coast Guard property: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1382-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 1470, Transfer of obscene material to minors: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1470-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 1503, Influencing or injuring officer or juror generally: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1503-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.