18 U.S.C. 2243, Sexual abuse of a minor, a ward, or an individual in Federal custody: How Federal Cases Ended, FY2016–2025
Of the 454 federal defendants whose most serious charge was under 18 U.S.C. 2243 and whose cases ended in fiscal years 2016 to 2025, 424 (93%) were convicted. Nearly all of them, 412 (91%), pleaded guilty. Only 13 went to trial, and 1 of those trials ended in an acquittal.
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In brief: Of the 454 federal defendants whose most serious charge was under 18 U.S.C. 2243 and whose cases ended in fiscal years 2016 to 2025, 424 (93%) were convicted. Nearly all of them, 412 (91%), pleaded guilty. Only 13 went to trial, and 1 of those trials ended in an acquittal.
This post uses the Federal Judicial Center's records of 454 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.
Guilty Pleas Decided Most of These Cases
The U.S. Code gives section 2243 of Title 18 the heading "Sexual abuse of a minor, a ward, or an individual in Federal custody". This post uses only that heading to identify the section. The counts come from the Federal Judicial Center, which records every federal defendant whose case ended, including dismissals and acquittals.
The group here is defendants whose most serious charge at the end of the case fell under section 2243. Over fiscal years 2016 to 2025, that group numbered 454. Of them, 412 (91%) pleaded guilty, 29 (6%) had their charges dismissed, and 13 (3%) went to trial.
A dismissal in these records does not always mean the government dropped the matter. The category includes cases dismissed on the government's motion, for example after the defendant pleaded guilty in a different case.
What Happened in the 13 Trials
All 13 trials were jury trials. No case under this section was decided by a judge alone in these years.
Of the 13 jury trials, 1 ended in an acquittal (8%). With so few trials, a single verdict moves that percentage a great deal, so it is a weak basis for any general statement about trials under this section.
Adding the trial convictions to the guilty pleas gives the total already reported in the sheet: 424 of the 454 defendants (93%) were convicted, by plea or at trial.
Charge Level and Prison Terms
Every one of the 454 cases was recorded as a felony on this charge. The records show no Class A misdemeanors and no petty offenses under section 2243.
Of the 424 defendants who were convicted, 402 (95%) received a prison term on this charge. Among those whose term was 1 month or more, the median prison term was 37.5 months (3.1 years). The median is the middle value when all terms are listed from shortest to longest.
The prison figures cover only the section 2243 charge. They do not add in time imposed on other counts.
Type of Counsel at the End of the Case
Federal public or community defenders represented 272 defendants (60%). CJA panel attorneys, who are private lawyers appointed by the court, represented 97 (21%). Retained private counsel represented 83 (18%).
Guilty plea rates were 92% for federal defenders, 93% for CJA panel attorneys, and 86% for retained counsel. Retained counsel had 7 trials, more than either appointed group, and none ended in acquittal. The single acquittal came in 1 of 4 trials handled by federal defenders.
These figures describe groups of cases, not the quality of the lawyers in them. Counsel type is recorded when the case ends, and defendants who hire a lawyer often face different charges and circumstances from those who receive an appointed one.
| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| Federal public or community defender | 272 | 92% | 6% | 4 | 1 (1 of 4) |
| CJA panel attorney | 97 | 93% | 5% | 2 | 0 (0 of 2) |
| Private (retained) counsel | 83 | 86% | 6% | 7 | 0 (0 of 7) |
Year by Year
The number of cases ending each fiscal year ranged from 31 in 2020 to 55 in 2024. Guilty plea rates stayed between 86% and 94% across the decade.
No year had more than 3 trials. The only acquittal came in fiscal year 2019.
| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| 2016 | 44 | 91% | 9% | 0 | 0 |
| 2017 | 38 | 92% | 5% | 1 | 0 (0 of 1) |
| 2018 | 47 | 91% | 9% | 0 | 0 |
| 2019 | 43 | 86% | 9% | 2 | 1 (1 of 2) |
| 2020 | 31 | 90% | 10% | 0 | 0 |
| 2021 | 43 | 93% | 7% | 0 | 0 |
| 2022 | 53 | 91% | 6% | 2 | 0 (0 of 2) |
| 2023 | 48 | 94% | 0% | 3 | 0 (0 of 3) |
| 2024 | 55 | 89% | 7% | 2 | 0 (0 of 2) |
| 2025 | 52 | 90% | 4% | 3 | 0 (0 of 3) |
Related Court-Martial Comparisons
This statute is part of the approved pairing for sexual abuse of an adult, which on the military side covers Article 120 rape, sexual assault, and abusive sexual contact. The comparison posts treat that pairing separately.
Limits of These Records
The records count how cases ended. They do not show the evidence, the plea terms, or the reasons a prosecutor dismissed a charge. They also cannot explain why a given defendant chose a plea over a trial.
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. 2243, any subsection (454), 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)
- Sexual Abuse of an Adult: Federal Cases vs. Article 120 Courts-Martial (comparison with courts-martial)
- 18 U.S.C. 2241, Aggravated sexual abuse: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 2242, Sexual abuse: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 2244, Abusive sexual contact: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 2250, Failure to register: 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?
- Fewer or More? Sexual Assault Charges at Army Courts-Martial, 2021–2025 (court-martial data)
- Fighting an Army Sexual Assault Charge: How Contested Cases Ended (court-martial data)
- Is Air Force Sexual Assault Prosecution Rising or Falling? Article 120, 2016–2025 (court-martial data)
- Is Navy-Marine Corps Sexual Assault Prosecution Rising or Falling? Article 120, 2017–2025 (court-martial data)
- Not Guilty Pleas in Navy-Marine Corps Article 120 Cases: What Happened at Trial (court-martial data)
- Article 120 (Rape and Sexual Assault): Court-Martial Data and Trends (court-martial data)
- Article 120 UCMJ Explained by a Former Special Victim Prosecutor (law firm reference page)
- 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.