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# 18 U.S.C. 2320, Trafficking in counterfeit goods or services: How Federal Cases Ended, FY2016–2025
- URL: https://www.bodiesburied.com/trends/federal-statute-18-usc-2320-case-outcomes/
- Published: 2026-11-03T06:55:43.000Z
- Updated: 2026-11-03T06:55:43.000Z
- Description: Of 322 defendants convicted under 18 U.S.C. 2320 in fiscal years 2016 to 2025, 188 (58%) received a prison term on that charge, and the median term was 15 months. In all, 389 defendants had a case end under this section: 80% pleaded guilty, 16% had the charges dismissed, and 13 went to trial. Of the
- 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. 2320

**In brief:** Of 322 defendants convicted under 18 U.S.C. 2320 in fiscal years 2016 to 2025, 188 (58%) received a prison term on that charge, and the median term was 15 months. In all, 389 defendants had a case end under this section: 80% pleaded guilty, 16% had the charges dismissed, and 13 went to trial. Of the 13 trials, 3 ended in an acquittal (23%).

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 389 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/).

## How Many Convicted Defendants Received Prison?

A conviction by plea or verdict was recorded for 322 of the 389 defendants (83%). Of those 322, 188 (58%) received a prison term on this charge.

For terms of 1 month or more, the median prison term was 15 months. The median is the middle value when terms are ranked from shortest to longest.

The prison count looks at this charge alone. A defendant can receive a term on another count in the same case, and that term is not part of these figures.

## The Section and the Charge Level

Section 2320 of Title 18 has the heading "Trafficking in counterfeit goods or services". The section is described here only by that heading.

Nearly every charge was a felony: 388 of 389 (more than 99%). A single case, 1 of the 389, was a Class A misdemeanor. None was a petty offense.

Defendants are counted here when this section was the most serious charge at the end of the case, following the method of the federal courts' Table D-4.

## Trials and Acquittals

Only 13 cases (3%) went to trial. Juries decided 11 and acquitted in 1 (9%). Judges decided 2 bench trials and acquitted in both (2 of 2).

Across all 13 trials, 3 ended in an acquittal (23%). That rate rests on 3 verdicts. A single verdict either way would move it by several points.

## Dismissals and the Yearly Counts

The charges were dismissed for 64 defendants (16%). The records count a case as dismissed when the charges were dismissed, including dismissals on the government's motion, for example after a guilty plea in another case.

Yearly totals ranged from 23 to 66 cases. Fiscal year 2017 had the most, 66, and fiscal year 2022 had the fewest, 23\. The dismissal rate reached 31% in fiscal year 2019 and 26% in fiscal year 2022, and it was 9% in fiscal year 2024.

From fiscal year 2019 on, no year had more than 1 trial. The records do not show why the counts changed.

| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| ----------- | ----------- | -------------- | --------- | ------ | ------------------ |
| 2016        | 58          | 83%            | 12%       | 3      | 2 (2 of 3)         |
| 2017        | 66          | 82%            | 12%       | 4      | 0 (0 of 4)         |
| 2018        | 55          | 85%            | 11%       | 2      | 0 (0 of 2)         |
| 2019        | 36          | 69%            | 31%       | 0      | 0                  |
| 2020        | 27          | 81%            | 19%       | 0      | 0                  |
| 2021        | 28          | 86%            | 14%       | 0      | 0                  |
| 2022        | 23          | 70%            | 26%       | 1      | 1 (1 of 1)         |
| 2023        | 30          | 77%            | 20%       | 1      | 0 (0 of 1)         |
| 2024        | 33          | 88%            | 9%        | 1      | 0 (0 of 1)         |
| 2025        | 33          | 73%            | 24%       | 1      | 0 (0 of 1)         |

## Type of Counsel

Retained private counsel represented the largest share of defendants: 230 (59%). CJA panel attorneys, private lawyers appointed by the court, represented 69 (18%), and federal public or community defenders represented 68 (17%). The records list 2 defendants as self-represented.

With retained counsel, 88% pleaded guilty and 9% had the case dismissed. With a CJA panel attorney, 78% pleaded guilty and 13% had the case dismissed. With a federal defender, 81% pleaded guilty and 18% had the case dismissed.

Trials were 6 with retained counsel, 6 with CJA panel attorneys, and 1 with a federal defender. All 3 acquittals were in the CJA panel group (3 of 6).

These are counts of groups of cases, not a measure of the quality of lawyers. People who hire a lawyer and people who receive an appointed lawyer face different charges and circumstances, and the type of counsel is recorded only at the end of the case.

| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| -------------------------------------- | ---------- | -------------- | --------- | ------ | ------------------ |
| Federal public or community defender   | 68         | 81%            | 18%       | 1      | 0 (0 of 1)         |
| CJA panel attorney                     | 69         | 78%            | 13%       | 6      | 3 (3 of 6)         |
| Private (retained) counsel             | 230        | 88%            | 9%        | 6      | 0 (0 of 6)         |
| Self-represented                       | 2          | 0 of 2         | 2 of 2    | 0      | 0                  |

## Limits

These records show how each case ended and the term on this charge. They do not show the facts, the evidence, or why a case was dismissed.

No close court-martial counterpart for this section appears in the approved crosswalk. The post therefore reports federal numbers on their own.

### 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. 2320, any subsection (389), 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. 2312, Transportation of stolen vehicles: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-2312-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 2314, Transportation of stolen goods, securities, moneys, fraudulent State tax stamps, or articles used in counterfeiting: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-2314-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 2421, Transportation generally: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-2421-case-outcomes/) (same title of the U.S. Code)
- [18 U.S.C. 2422, Coercion and enticement: How Federal Cases Ended, FY2016–2025](https://www.bodiesburied.com/trends/federal-statute-18-usc-2422-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.