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# 18 U.S.C. 1546, Fraud and misuse of visas, permits, and other documents: How Federal Cases Ended, FY2016–2025
- URL: https://www.bodiesburied.com/trends/federal-statute-18-usc-1546-case-outcomes/
- Published: 2026-11-03T06:55:14.000Z
- Updated: 2026-11-03T06:55:14.000Z
- Description: Federal cases under 18 U.S.C. 1546 seldom reached trial: 39 of 4,629 defendants (less than 1%) in fiscal years 2016 to 2025. Of those 39 trials, 12 ended in an acquittal (31%). Guilty pleas ended 4,401 cases (95%), and the median prison term on this charge was 5 months.
- 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. 1546

**In brief:** Federal cases under 18 U.S.C. 1546 seldom reached trial: 39 of 4,629 defendants (less than 1%) in fiscal years 2016 to 2025\. Of those 39 trials, 12 ended in an acquittal (31%). Guilty pleas ended 4,401 cases (95%), and the median prison term on this charge was 5 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 4,629 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/).

## Few Trials, and Their Verdicts

Of the 39 trials, juries decided 34 and acquitted in 8 (24%). Judges sitting without a jury decided 5 and acquitted in 4 of 5.

The acquittal rate of 31% is based on a small group. A few verdicts going the other way would change it. It also leaves out the 4,401 guilty pleas and the 189 dismissals, so it describes trials only.

## The Section Heading

The U.S. Code gives Title 18, section 1546 the heading "Fraud and misuse of visas, permits, and other documents." This post counts federal defendants whose most serious charge at the end of the case fell under that section.

The Federal Judicial Center reports these cases using the method of the federal courts' Table D-4\. Every case that ended is included, whether it ended in a conviction, a dismissal, or an acquittal.

## Pleas, Dismissals, and Convictions

Guilty pleas ended 4,401 cases (95%), and charges were dismissed for 189 defendants (4%). Some dismissals in these records came on the government's motion, which can follow a guilty plea in another case.

By plea or verdict, 4,428 of the 4,629 defendants were convicted (96%). The charge was a felony in all 4,629 cases.

## How Long Were the Prison Terms?

Of the 4,428 convicted, 3,921 (89%) were sentenced to a prison term on this charge. Counting terms of 1 month or more, the median was 5 months. A life term was recorded for 1 person.

A median shows the middle of the ranked terms, not their spread. These are terms on this charge as imposed by the court.

## Counsel and Case Results

Federal public or community defenders were counsel for 2,707 defendants (58%), CJA panel attorneys for 1,436 (31%), and retained private counsel for 431 (9%). A CJA panel attorney is a private lawyer appointed by the court.

Plea shares were 97% for both appointed groups and 90% for retained counsel. The federal defender group had 15 trials with 7 acquittals (47%). Retained counsel had 16 trials with 4 acquittals (25%), and CJA panel attorneys had 8 trials with 1 acquittal.

Each group handled different people facing different charges, so these figures describe groups of cases, not the quality of lawyers. With so few trials in each group, the acquittal shares are also too small to compare with confidence.

| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| -------------------------------------- | ---------- | -------------- | --------- | ------ | ------------------ |
| Federal public or community defender   | 2,707      | 97%            | 3%        | 15     | 7 (47%)            |
| CJA panel attorney                     | 1,436      | 97%            | 3%        | 8      | 1 (1 of 8)         |
| Private (retained) counsel             | 431        | 90%            | 6%        | 16     | 4 (25%)            |

## Fiscal Year Counts

Fiscal year 2019 had the most cases ending, 773, followed by fiscal year 2018 with 665\. Fiscal year 2024 had the fewest, 244\. The guilty-plea share was between 93% and 98% in every year.

Trials numbered from 2 to 8 a year, so the yearly acquittal counts are too small to show a trend.

| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| ----------- | ----------- | -------------- | --------- | ------ | ------------------ |
| 2016        | 444         | 94%            | 5%        | 5      | 1 (1 of 5)         |
| 2017        | 390         | 95%            | 4%        | 6      | 3 (3 of 6)         |
| 2018        | 665         | 94%            | 5%        | 8      | 2 (2 of 8)         |
| 2019        | 773         | 94%            | 5%        | 6      | 2 (2 of 6)         |
| 2020        | 484         | 97%            | 3%        | 2      | 0 (0 of 2)         |
| 2021        | 421         | 98%            | 2%        | 2      | 1 (1 of 2)         |
| 2022        | 496         | 98%            | 1%        | 2      | 1 (1 of 2)         |
| 2023        | 295         | 95%            | 4%        | 2      | 0 (0 of 2)         |
| 2024        | 244         | 93%            | 5%        | 3      | 1 (1 of 3)         |
| 2025        | 417         | 94%            | 6%        | 3      | 1 (1 of 3)         |

## Limits

There is no close court-martial counterpart in the approved crosswalk, so these are federal numbers alone. The records do not include case facts or the reasons for any verdict or 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. 1546, any subsection (4,629), 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. 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. 1544, Misuse of passport: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1544-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)
- [18 U.S.C. 1591, Sex trafficking of children or by force, fraud, or coercion: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-1591-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.