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Understanding Trends

18 U.S.C. 2252, Certain activities relating to material involving the sexual exploitation of minors: How Federal Cases Ended, FY2016–2025

From fiscal year 2016 through 2025, 2,890 of 3,071 federal defendants (94%) whose most serious charge fell under 18 U.S.C. 2252 pleaded guilty. In total, 2,960 (96%) were convicted. Only 72 went to trial, 2 trials ended in an acquittal, and the median prison term on the charge was 90 months (7.5 yea

Understanding Trends in Military Practice · 7 min read

Trends › Federal Prosecution Analysis › 18 U.S.C. 2252

In brief: From fiscal year 2016 through 2025, 2,890 of 3,071 federal defendants (94%) whose most serious charge fell under 18 U.S.C. 2252 pleaded guilty. In total, 2,960 (96%) were convicted. Only 72 went to trial, 2 trials ended in an acquittal, and the median prison term on the charge was 90 months (7.5 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 3,071 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 in 94% of Cases

The U.S. Code heading for Title 18, section 2252 reads "Certain activities relating to material involving the sexual exploitation of minors". The post describes the section by that heading and nothing more.

The Federal Judicial Center counted 3,071 defendants whose most serious charge at the close of the case was under section 2252. Of those, 2,890 (94%) pleaded guilty and 109 (4%) had their charges dismissed. The remaining 72 (2%) went to trial.

Dismissal here is a broad category. It includes dismissals on the government's motion, such as after the defendant pleaded guilty in a separate case.

Trials and Their Results

Of the 72 trials, 62 were before a jury and 10 were before a judge alone. Each type had 1 acquittal. That works out to 2% of jury trials and 10% of bench trials.

Across all 72 trials, 2 ended in an acquittal (3%). Adding trial convictions to guilty pleas, 2,960 of the 3,071 defendants were convicted.

Sentences on the Section 2252 Charge

Every case was recorded as a felony. No Class A misdemeanors or petty offenses appear.

Of the 2,960 convicted, 2,918 (99%) received a prison term on this charge. The median term, counting only terms of 1 month or more, was 90 months (7.5 years). The records list 3 life sentences.

These figures cover the section 2252 count only, not the full sentence a defendant may have received on all counts.

Lawyers by Type

Counsel type is recorded at the end of the case. Differences by type of counsel describe groups of cases, not the quality of lawyers. Defendants who retain a lawyer and those given an appointed lawyer often face different charges and circumstances.

Retained private counsel represented 994 defendants (32%), and 95% of them pleaded guilty. None of their 25 trials ended in acquittal (0%).

Federal public or community defenders represented 1,489 defendants (48%), with a 96% plea rate and 1 acquittal in 22 trials (5%). CJA panel attorneys, private lawyers appointed by the court, represented 562 (18%), with a 93% plea rate and 1 acquittal in 24 trials (4%).

Dismissal rates were 3% in each of those 3 groups. Another 2 defendants represented themselves; 1 had the case dismissed and 1 went to trial without an acquittal.

Type of counsel at the end of the caseDefendantsPleaded guiltyDismissedTrialsAcquitted at trial
Federal public or community defender1,48996%3%221 (5%)
CJA panel attorney56293%3%241 (4%)
Private (retained) counsel99495%3%250 (0%)
Self-represented20 of 21 of 210 (0 of 1)

Changes Across the Fiscal Years

The most cases ended in fiscal year 2016, at 400. The fewest ended in fiscal year 2020, at 229.

Fiscal year 2018 had the most trials, 19, and none ended in acquittal. Fiscal year 2021 had no trials. The 2 acquittals came in fiscal years 2019 and 2022.

Fiscal yearCases endedPleaded guiltyDismissedTrialsAcquitted at trial
201640093%4%100 (0%)
201732091%7%90 (0 of 9)
201834092%2%190 (0%)
201928394%3%81 (1 of 8)
202022996%2%50 (0 of 5)
202125597%3%00
202233195%3%51 (1 of 5)
202333493%4%80 (0 of 8)
202426895%3%50 (0 of 5)
202531196%3%30 (0 of 3)

Crosswalk to Military Cases

The approved crosswalk places this statute in the pairing for child pornography (images of child exploitation): possession, receipt, or distribution. Courts-martial charge child pornography under Article 134, and the comparison posts set the federal and military numbers side by side.

Beyond the Numbers

These records do not describe the conduct in any case, the evidence, or the terms of any plea. They cannot show why most defendants pleaded guilty or why the few acquittals happened.

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. 2252, any subsection (3,071), 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). Charge codes with a letter right after the section number (for example 18:2252A) were left out, because the U.S. Code also has a separately numbered section with that letter and the codes cannot tell the two apart.

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

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.

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