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
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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).
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 case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| Federal public or community defender | 1,489 | 96% | 3% | 22 | 1 (5%) |
| CJA panel attorney | 562 | 93% | 3% | 24 | 1 (4%) |
| Private (retained) counsel | 994 | 95% | 3% | 25 | 0 (0%) |
| Self-represented | 2 | 0 of 2 | 1 of 2 | 1 | 0 (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 year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| 2016 | 400 | 93% | 4% | 10 | 0 (0%) |
| 2017 | 320 | 91% | 7% | 9 | 0 (0 of 9) |
| 2018 | 340 | 92% | 2% | 19 | 0 (0%) |
| 2019 | 283 | 94% | 3% | 8 | 1 (1 of 8) |
| 2020 | 229 | 96% | 2% | 5 | 0 (0 of 5) |
| 2021 | 255 | 97% | 3% | 0 | 0 |
| 2022 | 331 | 95% | 3% | 5 | 1 (1 of 5) |
| 2023 | 334 | 93% | 4% | 8 | 0 (0 of 8) |
| 2024 | 268 | 95% | 3% | 5 | 0 (0 of 5) |
| 2025 | 311 | 96% | 3% | 3 | 0 (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
- 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)
- Child Pornography Sentences: Federal Court vs. Courts-Martial, 2016–2025 (comparison with courts-martial)
- 18 U.S.C. 2250, Failure to register: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 2251, Sexual exploitation of children: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 2261, Interstate domestic violence: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 2312, Transportation of stolen 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?
- Fewer or More? General Article Charges at Army Courts-Martial, 2021–2025 (court-martial data)
- Fighting an Army General Article Charge: How Contested Cases Ended (court-martial data)
- Air Force Article 134 Cases by the Numbers, 2016–2025 (court-martial data)
- Is Navy-Marine Corps General Article Prosecution Rising or Falling? Article 134, 2017–2025 (court-martial data)
- Not Guilty Pleas in Navy-Marine Corps Article 134 Cases: What Happened at Trial (court-martial data)
- Article 134 (General Article): Court-Martial Data and Trends (court-martial data)
- Article 134 UCMJ: The General Article (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.