18 U.S.C. 894, Collection of extensions of credit by extortionate means: How Federal Cases Ended, FY2016–2025
Federal trials under 18 U.S.C. 894 were few in fiscal years 2016 to 2025: 7 of the 70 defendants (10%) went to trial, and 4 of those 7 ended in an acquittal. Most defendants pleaded guilty: 59 (84%). Of the 62 convicted, 52 (84%) received a prison term on that charge, with a median of 30 months (2.5
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In brief: Federal trials under 18 U.S.C. 894 were few in fiscal years 2016 to 2025: 7 of the 70 defendants (10%) went to trial, and 4 of those 7 ended in an acquittal. Most defendants pleaded guilty: 59 (84%). Of the 62 convicted, 52 (84%) received a prison term on that charge, with a median of 30 months (2.5 years).
This post uses the Federal Judicial Center's records of 70 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.
Trials and Acquittals
The heading of this section is "Collection of extensions of credit by extortionate means". The Federal Judicial Center lists 70 defendants whose cases ended with it as the most serious charge.
Juries decided 6 trials and acquitted in 3 of 6. A judge decided 1 bench trial, which ended in an acquittal.
These counts are too small to support a reliable acquittal rate. In a group of 7 trials, each verdict carries a large weight, and the records do not describe the evidence in any of them.
Pleas and Dismissals
Guilty pleas ended 59 cases. Only 4 (6%) were dismissed.
In FJC records a dismissal means the charges were dropped, including on the government's motion. One example is a dismissal after a guilty plea in another case.
Convictions by plea or by verdict reached 62 of the 70 (89%).
Who Represented the Defendants?
Retained private counsel represented 39 defendants (56%), more than any other type in this group. CJA panel attorneys, private lawyers appointed by the court, represented 27 (39%). Federal public or community defenders represented 3 (4%).
Clients of retained counsel had a plea rate of 82%, a dismissal rate of 8%, and 4 trials with 2 acquittals. Clients of CJA panel attorneys had a plea rate of 89%, no dismissals, and 3 trials with 2 acquittals. All 3 defendants with a federal defender pleaded guilty.
Hired and appointed lawyers represent different groups of defendants, who face different charges and circumstances. Type of counsel is noted at the end of the case. These figures 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 | 3 | 3 of 3 | 0 of 3 | 0 | 0 |
| CJA panel attorney | 27 | 89% | 0% | 3 | 2 (2 of 3) |
| Private (retained) counsel | 39 | 82% | 8% | 4 | 2 (2 of 4) |
Charge Level and Prison Terms
Every charge in the group was a felony: 70 (100%). No misdemeanors or petty offenses were recorded.
Of the 62 convicted, 52 received a prison term on this charge. The median term, among terms of 1 month or more, was 30 months (2.5 years). That is the middle term when the terms are ranked by length.
By Fiscal Year
Yearly counts ranged from 3 to 10 cases. All 10 cases in fiscal year 2017 ended in a guilty plea.
Fiscal year 2022 had 2 of 6 cases dismissed and 1 trial, which ended in an acquittal. The trials in fiscal years 2023 and 2025 did not end in an acquittal.
Counts this small do not show a trend, and the records do not explain the yearly differences.
| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| 2016 | 10 | 80% | 0% | 2 | 1 (1 of 2) |
| 2017 | 10 | 100% | 0% | 0 | 0 |
| 2018 | 9 | 8 of 9 | 0 of 9 | 1 | 1 (1 of 1) |
| 2019 | 8 | 7 of 8 | 0 of 8 | 1 | 1 (1 of 1) |
| 2020 | 3 | 3 of 3 | 0 of 3 | 0 | 0 |
| 2021 | 6 | 6 of 6 | 0 of 6 | 0 | 0 |
| 2022 | 6 | 3 of 6 | 2 of 6 | 1 | 1 (1 of 1) |
| 2023 | 3 | 2 of 3 | 0 of 3 | 1 | 0 (0 of 1) |
| 2024 | 9 | 7 of 9 | 2 of 9 | 0 | 0 |
| 2025 | 6 | 5 of 6 | 0 of 6 | 1 | 0 (0 of 1) |
Limits of These Records
The data counts only the most serious charge at the end of each case. It does not describe the conduct, the people involved, or why a case went to trial.
No close court-martial counterpart for this section appears in the approved crosswalk, so the numbers are federal only.
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. 894, any subsection (70), 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)
- 18 U.S.C. 875, Interstate communications: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 876, Mailing threatening communications: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 911, Citizen of the United States: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 18 U.S.C. 912, Officer or employee of the United States: 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?
- 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.