18 U.S.C. 1704, Keys or locks stolen or reproduced: How Federal Cases Ended, FY2016–2025
Among 205 federal defendants whose most serious charge at the end of the case was under 18 U.S.C. 1704, 191 (93%) were convicted in fiscal years 2016 to 2025, all of them by guilty plea. 140 of those 191 (73%) received a prison term on this charge, and the median term was 15 months. Only 1 case went
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In brief: Among 205 federal defendants whose most serious charge at the end of the case was under 18 U.S.C. 1704, 191 (93%) were convicted in fiscal years 2016 to 2025, all of them by guilty plea. 140 of those 191 (73%) received a prison term on this charge, and the median term was 15 months. Only 1 case went to trial, and it ended in an acquittal.
This post uses the Federal Judicial Center's records of 205 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.
Prison Terms Were Common
Title 18, section 1704 is headed "Keys or locks stolen or reproduced" in the U.S. Code. That heading is the only description of the section used here.
Of the 191 convicted defendants, 140 (73%) received a prison term on the section 1704 charge. For those with a term of 1 month or more, the median was 15 months. The median is the middle term when the terms are ranked by length.
The count is limited to the term on this charge. Defendants could also have been sentenced on other charges in the same case, and that time is not included.
Every Charge Was a Felony
The records show all 205 charges under this section as felonies. No case was recorded as a Class A misdemeanor or a petty offense.
How the Cases Ended
191 defendants (93%) pleaded guilty. 13 (6%) had their cases dismissed. 1 defendant (less than 1%) went to trial.
Because the only trial ended in an acquittal, every conviction under this section in these years came from a guilty plea. The trial was a jury trial. No bench trials were recorded.
These figures come from the Federal Judicial Center, which counts every defendant whose case ended, including dismissals and acquittals. Dismissals include cases dropped on the government's motion, such as after a guilty plea in another case.
More Cases in Recent Years
The number of cases ending under this section each year was higher in the most recent years. 4 cases ended in 2016, 13 in 2017, and 25 in 2018. Then 30 ended in 2023, 34 in 2024, and 50 in 2025.
The records show the count of cases that ended, not the reason the count changed. The guilty plea share stayed at 85% or above in each year with 10 or more cases. The 1 trial and acquittal both fell in 2018.
| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| 2016 | 4 | 4 of 4 | 0 of 4 | 0 | 0 |
| 2017 | 13 | 85% | 15% | 0 | 0 |
| 2018 | 25 | 92% | 4% | 1 | 1 (1 of 1) |
| 2019 | 13 | 100% | 0% | 0 | 0 |
| 2020 | 9 | 7 of 9 | 2 of 9 | 0 | 0 |
| 2021 | 15 | 100% | 0% | 0 | 0 |
| 2022 | 12 | 100% | 0% | 0 | 0 |
| 2023 | 30 | 93% | 7% | 0 | 0 |
| 2024 | 34 | 91% | 9% | 0 | 0 |
| 2025 | 50 | 94% | 6% | 0 | 0 |
Counsel at the End of the Case
The type of counsel is the one recorded when the case closed. Defendants with hired lawyers and those with appointed lawyers face different charges and circumstances. Any difference between the groups describes the cases, not the quality of the lawyers.
Federal public or community defenders represented 97 defendants (47%). 96% pleaded guilty and 4% had their cases dismissed. None went to trial.
CJA panel attorneys, who are private lawyers appointed by the court, represented 80 defendants (39%). 93% pleaded guilty and 8% were dismissed. None went to trial.
Private (retained) counsel represented 25 defendants (12%). 96% pleaded guilty and 0% were dismissed. The 1 trial, which ended in an acquittal, was in this group. A single case cannot show anything about retained lawyers in general.
| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| Federal public or community defender | 97 | 96% | 4% | 0 | 0 |
| CJA panel attorney | 80 | 93% | 8% | 0 | 0 |
| Private (retained) counsel | 25 | 96% | 0% | 1 | 1 (1 of 1) |
What the Data Does Not Show
Defendants are grouped by the most serious charge at the end of the case. A case that started under another section, or ended under one, is placed by its final charge.
The records carry no details about the facts, the evidence, or the reasons behind a plea or a dismissal. The approved crosswalk has no close court-martial counterpart for section 1704, so only federal numbers appear here.
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. 1704, any subsection (205), 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. 1701, Obstruction of mails generally: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 1703, Delay or destruction of mail or newspapers: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 1708, Theft or receipt of stolen mail matter generally: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 1709, Theft of mail matter by officer or employee: 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.