18 U.S.C. 2114, Mail, money, or other property of United States: How Federal Cases Ended, FY2016–2025
None of the 8 federal trials under 18 U.S.C. 2114 in fiscal years 2016 to 2025 ended in an acquittal (0 of 8). Of the 204 defendants whose cases ended with this section as the most serious charge, 184 (90%) pleaded guilty and 192 (94%) were convicted. Of those convicted, 187 (97%) received a prison
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In brief: None of the 8 federal trials under 18 U.S.C. 2114 in fiscal years 2016 to 2025 ended in an acquittal (0 of 8). Of the 204 defendants whose cases ended with this section as the most serious charge, 184 (90%) pleaded guilty and 192 (94%) were convicted. Of those convicted, 187 (97%) received a prison term on this charge, with a median of 63 months (5.2 years).
This post uses the Federal Judicial Center's records of 204 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.
No Acquittals at Trial
Only 8 defendants (4%) went to trial under this section. Every one of the 8 trials was decided by a jury, and none ended in an acquittal (0 of 8). No case was tried before a judge alone.
A trial count of 8 is small. The result describes these cases and is not a rate that predicts other trials.
Section 2114 and How Cases Were Counted
The U.S. Code heading for Title 18, section 2114 is "Mail, money, or other property of United States". Each defendant in this post had a charge under the section, in any subsection, as the most serious charge left when the case ended.
The source is the Federal Judicial Center, counted as in the federal courts' Table D-4. Dismissals and acquittals are included along with convictions. The level of the charge was a felony for all 204 defendants.
Pleas and Dismissals
Guilty pleas ended 184 cases (90%). Dismissals ended 12 (6%).
A dismissal here means the charges were dropped. It can include charges the government dismissed after the defendant pleaded guilty in another case, so it does not always mean the person left federal court without a conviction.
What Prison Terms Were Given?
Among the 192 people convicted, 187 (97%) received a prison term on this charge. For terms of 1 month or more, the median was 63 months (5.2 years).
A median is the middle term in a ranked list. The records report it only for this charge, so terms on any other count in the same case are not reflected.
Counsel Recorded When the Case Ended
CJA panel attorneys represented 101 defendants (50%). A CJA panel attorney is a private lawyer appointed by the court. In this group, 89% pleaded guilty, 4% were dismissed, and 7 went to trial, with no acquittals (0 of 7).
Federal public or community defenders represented 74 defendants (36%). Of those, 93% pleaded guilty, 5% were dismissed, and 1 went to trial without an acquittal. Private (retained) counsel represented 26 defendants (13%): 96% pleaded guilty, 4% were dismissed, and none went to trial.
People who hire a lawyer and people who are assigned one tend to face different charges and circumstances. The numbers here describe groups of cases, not the quality of lawyers.
| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| Federal public or community defender | 74 | 93% | 5% | 1 | 0 (0 of 1) |
| CJA panel attorney | 101 | 89% | 4% | 7 | 0 (0 of 7) |
| Private (retained) counsel | 26 | 96% | 4% | 0 | 0 |
Cases Ended Each Fiscal Year
From fiscal year 2016 to fiscal year 2022, between 12 and 15 cases ended each year. The count was higher in fiscal years 2023 to 2025: 27 in fiscal year 2023, 36 in fiscal year 2024, and 45 in fiscal year 2025.
The records do not explain the higher counts in those years. Dismissal shares moved from year to year, from 0% in several years to 17% in fiscal years 2021 and 2024. Counts this small should not be read as a trend.
| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| 2016 | 15 | 87% | 13% | 0 | 0 |
| 2017 | 13 | 100% | 0% | 0 | 0 |
| 2018 | 15 | 93% | 0% | 1 | 0 (0 of 1) |
| 2019 | 15 | 100% | 0% | 0 | 0 |
| 2020 | 13 | 85% | 0% | 2 | 0 (0 of 2) |
| 2021 | 12 | 83% | 17% | 0 | 0 |
| 2022 | 13 | 92% | 0% | 1 | 0 (0 of 1) |
| 2023 | 27 | 89% | 0% | 3 | 0 (0 of 3) |
| 2024 | 36 | 81% | 17% | 1 | 0 (0 of 1) |
| 2025 | 45 | 96% | 4% | 0 | 0 |
What the Records Cannot Show
The data places each defendant under the most serious charge at the end of the case. It does not describe the conduct, the evidence, or why charges were dismissed. The approved crosswalk has no close court-martial counterpart for this section, so the numbers here are federal only.
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. 2114, any subsection (204), 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. 2111, Special maritime and territorial jurisdiction: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 2113, Bank robbery and incidental crimes: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 2118, Robberies and burglaries involving controlled substances: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 2119, Motor vehicles: 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.