NewKnow Your Judge: the court-martial record of 294 military judges → NewLearn Your Lawyer: the court-martial record of 335 military lawyers →
Where All The Bodies Are Buried
Understanding Trends

18 U.S.C. 1594, General provisions: How Federal Cases Ended, FY2016–2025

In fiscal years 2016 to 2025, 80 of 551 federal defendants charged under 18 U.S.C. 1594 went to trial (15%), and 4 of those trials ended in an acquittal (5%). Overall, 496 (90%) were convicted. Among them, 488 (98%) received a prison term on this charge, with a median of 120 months (10 years).

Understanding Trends in Military Practice · 6 min read

Trends › Federal Prosecution Analysis › 18 U.S.C. 1594

In brief: In fiscal years 2016 to 2025, 80 of 551 federal defendants charged under 18 U.S.C. 1594 went to trial (15%), and 4 of those trials ended in an acquittal (5%). Overall, 496 (90%) were convicted. Among them, 488 (98%) received a prison term on this charge, with a median of 120 months (10 years).

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 551 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.

The Section and the Records

Section 1594 of Title 18 carries the heading "General provisions." This post counts the 551 defendants for whom that section was the most serious charge at the end of the case.

The source is the Federal Judicial Center, counted the same way as the federal courts' Table D-4. Cases that ended in a dismissal or an acquittal are in these numbers, along with convictions.

Jury Verdicts Under Section 1594

Of the 80 trials, 79 were jury trials, and 3 of those ended in an acquittal (4%). There was 1 bench trial, decided by a judge, and it ended in an acquittal.

Across all 80 trials, the acquittal rate was 5%. That rate covers only defendants who went to trial. It does not include those who pleaded guilty or had their charges dismissed.

Most Defendants Pleaded Guilty

Guilty pleas ended 420 cases (76%). Another 51 defendants (9%) had their charges dismissed, which can include dismissal on the government's motion after a guilty plea in a separate case.

Every charge counted here was a felony (100%). No Class A misdemeanors or petty offenses were recorded.

Sentences on the Charge

Of the 496 convicted, 488 (98%) were sentenced to a prison term on this charge. The median prison term was 120 months, or 10 years, among terms of 1 month or more. Life terms were recorded for 21 people.

A median marks the middle of the ranked terms. It gives no information about the range of terms, and it reflects the sentence imposed rather than time served.

Appointed and Retained Counsel

Most defendants, 361 (66%), had a CJA panel attorney at the end of the case. A CJA panel attorney is a private lawyer appointed by the court. Federal public or community defenders represented 102 (19%), and retained private counsel represented 82 (15%).

The CJA panel group had 59 trials with 3 acquittals (5%). Federal defenders had 10 trials with 1 acquittal (10%). Retained counsel had 11 trials and no acquittals (0%). Guilty pleas were 75% for CJA panel attorneys, 83% for federal defenders, and 78% for retained counsel.

The counsel figures describe groups of cases, not the quality of lawyers. People with appointed counsel and people who hire a lawyer may face different charges and circumstances.

Type of counsel at the end of the caseDefendantsPleaded guiltyDismissedTrialsAcquitted at trial
Federal public or community defender10283%7%101 (10%)
CJA panel attorney36175%9%593 (5%)
Private (retained) counsel8278%9%110 (0%)

Changes From Year to Year

Fiscal year 2016 had the most cases end, 86, and fiscal year 2020 had the fewest, 23. Fiscal year 2020 also had the highest dismissal share, 22%.

Fiscal year 2022 had 13 trials and 2 acquittals (15%), the most acquittals of any year. Most years had none. The yearly counts are small and do not show a trend.

Fiscal yearCases endedPleaded guiltyDismissedTrialsAcquitted at trial
20168678%14%71 (1 of 7)
20175985%8%40 (0 of 4)
20186971%12%120 (0%)
20195070%8%110 (0%)
20202361%22%40 (0 of 4)
20213974%8%71 (1 of 7)
20228378%6%132 (15%)
20234980%4%80 (0 of 8)
20245372%9%100 (0%)
20254085%5%40 (0 of 4)

What the Data Does Not Show

There is no close court-martial counterpart for this section in the approved crosswalk, so only federal cases are reported. The records do not hold case facts or the reasons behind 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. 1594, any subsection (551), 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.

↑ Top