18 U.S.C. 1589, Forced labor: How Federal Cases Ended, FY2017–2025
All 11 federal trials under 18 U.S.C. 1589 in fiscal years 2017 to 2025 ended in a conviction. Of the 43 defendants, 25 (58%) pleaded guilty, 7 (16%) had their cases dismissed, and 11 (26%) went to trial. Of the 36 convicted, 33 (92%) received a prison term on this charge, with a median of 90.5 mont
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In brief: All 11 federal trials under 18 U.S.C. 1589 in fiscal years 2017 to 2025 ended in a conviction. Of the 43 defendants, 25 (58%) pleaded guilty, 7 (16%) had their cases dismissed, and 11 (26%) went to trial. Of the 36 convicted, 33 (92%) received a prison term on this charge, with a median of 90.5 months (7.5 years).
This post uses the Federal Judicial Center's records of 43 federal defendants whose cases ended in fiscal years 2017 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.
No Acquittals at Trial
A jury heard each of the 11 trials, and none ended in an acquittal (0%). No bench trials were recorded. Trials made up 26% of the cases, more than dismissals at 16%.
The group is small: 43 defendants across fiscal years 2017 to 2025. A different verdict in a single trial would change the 0% figure, so it describes these cases, not a fixed pattern.
Heading and Source
Title 18, section 1589 of the U.S. Code is headed "Forced labor." A defendant is included when that section was the most serious charge at the end of the case.
The Federal Judicial Center counts used here follow the federal courts' Table D-4. They include every case that ended, so dismissals appear along with convictions. The first fiscal year with cases in the table is 2017.
Pleas, Dismissals, and Charge Level
Guilty pleas ended 25 cases (58%). Charges were dismissed for 7 defendants (16%). Dismissals can include charges dropped on the government's motion, such as after a guilty plea in another case.
Counting pleas and verdicts, 36 of the 43 were convicted (84%). Every charge was a felony.
Length of Prison Terms
Of the 36 convicted, 33 (92%) were sentenced to prison on this charge. Among terms of 1 month or more, the median prison term was 90.5 months, or 7.5 years.
The median is the midpoint of the ranked terms. It does not show the shortest or longest term, and with this few people, a handful of sentences can move it.
Counsel Groups Were Small
Retained private counsel represented 16 defendants (37%), federal public or community defenders 12 (28%), and CJA panel attorneys, private lawyers appointed by the court, 11 (26%).
Retained counsel had 7 of the 11 trials. Federal defenders had 3, and CJA panel attorneys had 1. Guilty pleas were 50% for retained counsel, 67% for federal defenders, and 82% for CJA panel attorneys.
These figures describe groups of cases, not the quality of lawyers. Defendants who hire counsel and those with appointed counsel can face different charges and circumstances, and each group here is small.
| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| Federal public or community defender | 12 | 67% | 8% | 3 | 0 (0 of 3) |
| CJA panel attorney | 11 | 82% | 9% | 1 | 0 (0 of 1) |
| Private (retained) counsel | 16 | 50% | 6% | 7 | 0 (0 of 7) |
Year by Year
No fiscal year had more than 6 cases end, and fiscal year 2021 had 1. Fiscal year 2019 had the most trials, 3. In fiscal year 2022, 3 of 5 cases were dismissed.
Counts this small do not show a trend.
| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| 2017 | 5 | 3 of 5 | 1 of 5 | 1 | 0 (0 of 1) |
| 2018 | 5 | 5 of 5 | 0 of 5 | 0 | 0 |
| 2019 | 6 | 2 of 6 | 1 of 6 | 3 | 0 (0 of 3) |
| 2020 | 5 | 3 of 5 | 0 of 5 | 2 | 0 (0 of 2) |
| 2021 | 1 | 1 of 1 | 0 of 1 | 0 | 0 |
| 2022 | 5 | 1 of 5 | 3 of 5 | 1 | 0 (0 of 1) |
| 2023 | 6 | 4 of 6 | 0 of 6 | 2 | 0 (0 of 2) |
| 2024 | 5 | 4 of 5 | 0 of 5 | 1 | 0 (0 of 1) |
| 2025 | 5 | 2 of 5 | 2 of 5 | 1 | 0 (0 of 1) |
What the Records Omit
No close court-martial counterpart appears in the approved crosswalk, so the post covers federal cases only. The records give no case facts and no reasons for any plea, dismissal, or 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. 1589, any subsection (43), 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 (the background article)
- Federal Prosecution Analysis (all federal posts)
- How the Federal Comparison Data Was Built (sources and method)
- 18 U.S.C. 1544, Misuse of passport: How Federal Cases Ended, FY2016–2025 (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 (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 (same title of the U.S. Code)
- 18 U.S.C. 1594, General provisions: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- Appointed vs. Retained Lawyers in Federal Criminal Cases: How Cases Ended, 2016–2025
- Are Courts-Martial More Likely to End in Acquittal Than Federal Trials?
- U.S. Sentencing Commission, Individual Offender Datafiles (source)
- Federal Judicial Center, Integrated Database (criminal defendants) (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. This analysis is for education and information only. It is not legal advice, and every case is different.