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# 18 U.S.C. 1544, Misuse of passport: How Federal Cases Ended, FY2016–2025
- URL: https://www.bodiesburied.com/trends/federal-statute-18-usc-1544-case-outcomes/
- Published: 2026-11-03T06:55:21.000Z
- Updated: 2026-11-03T06:55:21.000Z
- Description: Of the 1,488 federal defendants convicted under 18 U.S.C. 1544 in fiscal years 2016 to 2025, 1,393 (94%) received a prison term on that charge, with a median of 6 months. Guilty pleas ended 1,487 of the 1,542 cases (96%). Just 1 case went to trial.
- 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. 1544

**In brief:** Of the 1,488 federal defendants convicted under 18 U.S.C. 1544 in fiscal years 2016 to 2025, 1,393 (94%) received a prison term on that charge, with a median of 6 months. Guilty pleas ended 1,487 of the 1,542 cases (96%). Just 1 case went to trial.

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 1,542 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/).

## Prison Terms After Conviction

A prison term on this charge was imposed on 1,393 people, which is 94% of the 1,488 convicted. Among terms of 1 month or more, the median was 6 months. A life term was recorded for 1 person.

The median is the midpoint of the ranked terms. It does not describe the longest terms, and it reflects the sentence imposed, not time served.

## The Heading and How Cases Were Counted

Title 18, section 1544 of the U.S. Code is headed "Misuse of passport." Defendants appear in this post when that section was their most serious charge at the end of the case.

The Federal Judicial Center records follow the counting in the federal courts' Table D-4\. They include every case that ended in fiscal years 2016 to 2025, whether by plea, dismissal, or trial. Each fiscal year begins on October 1 of the prior calendar year.

## Pleas, Dismissals, and the Single Trial

Guilty pleas ended 1,487 cases (96%), and 54 (4%) were dismissed. A dismissal here can include charges the government dropped after the defendant pleaded guilty in a separate case.

Only 1 case went to trial. A jury heard it, and it ended in a conviction. Overall, 1,488 of the 1,542 defendants (96%) were convicted, and every charge was a felony (100%).

With 1 trial, the records give no basis for describing trial results under this section.

## Type of Counsel

Federal public or community defenders represented 910 defendants (59%). CJA panel attorneys, private lawyers whom the court appointed, represented 582 (38%). Retained private counsel represented 48 (3%).

Guilty-plea shares were 96% for federal defenders, 97% for CJA panel attorneys, and 100% for retained counsel. Dismissals were 4% and 3% in the appointed groups and 0% in the retained group. The only trial involved a CJA panel attorney.

These figures describe groups of cases, not the quality of the lawyers involved. The people in each group can differ in their charges and circumstances, and counsel type is the one recorded when the case ended.

| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| -------------------------------------- | ---------- | -------------- | --------- | ------ | ------------------ |
| Federal public or community defender   | 910        | 96%            | 4%        | 0      | 0                  |
| CJA panel attorney                     | 582        | 97%            | 3%        | 1      | 0 (0 of 1)         |
| Private (retained) counsel             | 48         | 100%           | 0%        | 0      | 0                  |

## Fewer Cases in Later Years

The number of cases ending each fiscal year fell over the period. Fiscal year 2018 had 361 and fiscal year 2019 had 321\. By fiscal year 2024 the count was 27, and fiscal year 2025 had 26.

Guilty-plea shares were 90% or higher in every year. The lowest was 90% in fiscal year 2019, the same year the dismissal share reached 9%. The records do not explain why fewer cases ended in later years.

| Fiscal year | Cases ended | Pleaded guilty | Dismissed    | Trials | Acquitted at trial |
| ----------- | ----------- | -------------- | ------------ | ------ | ------------------ |
| 2016        | 233         | more than 99%  | less than 1% | 0      | 0                  |
| 2017        | 186         | 99%            | 1%           | 0      | 0                  |
| 2018        | 361         | 99%            | 1%           | 0      | 0                  |
| 2019        | 321         | 90%            | 9%           | 1      | 0 (0 of 1)         |
| 2020        | 180         | 94%            | 6%           | 0      | 0                  |
| 2021        | 95          | 99%            | 1%           | 0      | 0                  |
| 2022        | 72          | 100%           | 0%           | 0      | 0                  |
| 2023        | 41          | 93%            | 7%           | 0      | 0                  |
| 2024        | 27          | 100%           | 0%           | 0      | 0                  |
| 2025        | 26          | 96%            | 4%           | 0      | 0                  |

## What These Records Leave Out

The approved crosswalk has no close court-martial counterpart for this section, so this post covers federal cases only. The records list charges and results but not the facts of any case, the evidence, or the reasons for 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. 1544, any subsection (1,542), 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. 1542, False statement in application and use of passport: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1542-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 1543, Forgery or false use of passport: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1543-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 1546, Fraud and misuse of visas, permits, and other documents: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1546-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 1589, Forced labor: How Federal Cases Ended, FY2017–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1589-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.