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# 18 U.S.C. 2237, Criminal sanctions for failure to heave to, obstruction of boarding, or providing false information: How Federal Cases Ended, FY2016–2025
- URL: https://www.bodiesburied.com/trends/federal-statute-18-usc-2237-case-outcomes/
- Published: 2026-11-03T06:56:09.000Z
- Updated: 2026-11-03T06:56:09.000Z
- Description: Of 93 defendants convicted under 18 U.S.C. 2237 in cases that ended in fiscal years 2016 to 2025, 92 (99%) received a prison term on that charge, with a median of 13 months. In all, 101 defendants had cases end under this section. Of those, 92 (91%) pleaded guilty, 8 (8%) had their cases dismissed,
- 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. 2237

**In brief:** Of 93 defendants convicted under 18 U.S.C. 2237 in cases that ended in fiscal years 2016 to 2025, 92 (99%) received a prison term on that charge, with a median of 13 months. In all, 101 defendants had cases end under this section. Of those, 92 (91%) pleaded guilty, 8 (8%) had their cases dismissed, and 1 went to trial.

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 101 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/).

## Nearly Every Conviction Brought a Prison Term

Section 2237 of Title 18 carries the heading "Criminal sanctions for failure to heave to, obstruction of boarding, or providing false information". These numbers come from the Federal Judicial Center and count defendants by the most serious charge left at the end of the case.

Of the 93 convicted, 92 were sentenced to prison on this charge, or 99%. Among defendants with a term of 1 month or more, the median prison term was 13 months.

The median is the middle term when all terms are put in order. It does not describe the range, and these records do not give the shortest or longest term.

## Felony Charges Only

Every one of the 101 defendants faced a felony on this charge. The records list 0 Class A misdemeanors and 0 petty offenses.

Of the 101, 93 were convicted (92%). The convictions came by plea or at trial.

## Pleas, Dismissals, and a Single Trial

A guilty plea ended 92 cases, or 91%. Another 8 defendants (8%) had their cases dismissed.

In these records, a dismissal means the charges were dismissed. That includes dismissals on the government's motion, for example after a defendant pleaded guilty in another case. A dismissal is not an acquittal.

The 1 trial was a jury trial in fiscal year 2016\. It ended in a conviction, not an acquittal. A single trial cannot support an acquittal rate for this section.

## Counts by Fiscal Year

Yearly counts were small. They ranged from 3 cases in fiscal year 2022 to 20 in fiscal year 2024.

Dismissals appear in only some years. In fiscal year 2024, 15% of cases ended in dismissal, and in fiscal year 2025 the share was 17%. Counts this small can shift with a few cases, so the table shows each year but does not establish a trend.

| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| ----------- | ----------- | -------------- | --------- | ------ | ------------------ |
| 2016        | 9           | 8 of 9         | 0 of 9    | 1      | 0 (0 of 1)         |
| 2017        | 7           | 6 of 7         | 1 of 7    | 0      | 0                  |
| 2018        | 16          | 100%           | 0%        | 0      | 0                  |
| 2019        | 9           | 9 of 9         | 0 of 9    | 0      | 0                  |
| 2020        | 4           | 3 of 4         | 1 of 4    | 0      | 0                  |
| 2021        | 4           | 4 of 4         | 0 of 4    | 0      | 0                  |
| 2022        | 3           | 3 of 3         | 0 of 3    | 0      | 0                  |
| 2023        | 11          | 100%           | 0%        | 0      | 0                  |
| 2024        | 20          | 85%            | 15%       | 0      | 0                  |
| 2025        | 18          | 83%            | 17%       | 0      | 0                  |

## Who Represented the Defendants?

Federal public or community defenders represented 49 defendants (49%). CJA panel attorneys, who are private lawyers appointed by the court, represented 44 (44%). Retained private counsel represented 6 (6%).

Guilty pleas made up 92% of the public or community defender group and 93% of the CJA panel group. All 6 defendants with retained counsel pleaded guilty. The dismissal shares were 6% for public or community defenders and 7% for CJA panel attorneys. The 1 trial involved a public or community defender.

Counsel type is recorded at the end of the case. Defendants who hire a lawyer and those who receive an appointed lawyer face different charges and circumstances. Differences between these groups 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   | 49         | 92%            | 6%        | 1      | 0 (0 of 1)         |
| CJA panel attorney                     | 44         | 93%            | 7%        | 0      | 0                  |
| Private (retained) counsel             | 6          | 6 of 6         | 0 of 6    | 0      | 0                  |

## Limits of These Records

The Federal Judicial Center counts every defendant whose case ended, including dismissals and acquittals. Because cases are sorted by the final most serious charge, a defendant first charged under section 2237 who ended with a more serious charge is not counted here.

The records do not describe the facts or evidence in any case. The approved crosswalk lists no close court-martial counterpart for this section, so the post reports federal numbers alone.

### 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. 2237, any subsection (101), 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. 2118, Robberies and burglaries involving controlled substances: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-2118-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 2119, Motor vehicles: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-2119-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 2241, Aggravated sexual abuse: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-2241-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 2242, Sexual abuse: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-2242-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.