22 U.S.C. 2778, Control of arms exports and imports: How Federal Cases Ended, FY2016–2025
191 federal defendants had their cases end in fiscal years 2016 to 2025 with 22 U.S.C. 2778 as the most serious charge. 146 (76%) pleaded guilty, 37 (19%) had their cases dismissed, and 8 (4%) went to trial. Among the 153 convicted, 140 (92%) received a prison term on that charge, with a median of 3
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In brief: 191 federal defendants had their cases end in fiscal years 2016 to 2025 with 22 U.S.C. 2778 as the most serious charge. 146 (76%) pleaded guilty, 37 (19%) had their cases dismissed, and 8 (4%) went to trial. Among the 153 convicted, 140 (92%) received a prison term on that charge, with a median of 32 months (2.7 years).
This post uses the Federal Judicial Center's records of 191 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.
Section 2778 and the Group Counted
Title 22, section 2778 of the U.S. Code is headed "Control of arms exports and imports". This post refers to the statute only by that heading.
Every charge in the group was a felony: 191 (100%). The Federal Judicial Center records place a defendant here when this section was the most serious charge at the end of the case. Dismissals and acquittals are counted.
Dismissals in Recent Years
Across all 10 fiscal years, 37 defendants (19%) had their cases dismissed. Dismissed means the charges were dropped, including on the government's motion, such as after a guilty plea in another case.
Fewer cases ended in the later years. 43 ended in 2016, 12 in 2021, and 7 in 2025.
In 2023, 53% of the 19 cases ended in dismissal. In 2025, 4 of 7 did. These yearly counts are small, and the records do not explain them.
| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| 2016 | 43 | 86% | 12% | 1 | 0 (0 of 1) |
| 2017 | 31 | 81% | 13% | 2 | 1 (1 of 2) |
| 2018 | 26 | 81% | 15% | 1 | 0 (0 of 1) |
| 2019 | 17 | 88% | 6% | 1 | 0 (0 of 1) |
| 2020 | 19 | 79% | 16% | 1 | 0 (0 of 1) |
| 2021 | 12 | 67% | 25% | 1 | 0 (0 of 1) |
| 2022 | 8 | 6 of 8 | 1 of 8 | 1 | 0 (0 of 1) |
| 2023 | 19 | 47% | 53% | 0 | 0 |
| 2024 | 9 | 7 of 9 | 2 of 9 | 0 | 0 |
| 2025 | 7 | 3 of 7 | 4 of 7 | 0 | 0 |
Prison Terms
Of the 153 defendants convicted, 140 (92%) received a prison term on this charge. The median term, among those with 1 month or more, was 32 months (2.7 years).
No defendant in this group is listed with a life term. The median is the middle term, not an average.
Trials Were Few
Only 8 defendants went to trial, and 1 ended in an acquittal (1 of 8). Juries decided 6 trials, with 0 acquittals (0 of 6). Judges decided 2 bench trials, with 1 acquittal (1 of 2).
With 8 trials in 10 fiscal years, the records cannot support a meaningful acquittal rate for this section. Counting pleas and trial verdicts, 153 of the 191 (80%) were convicted.
Counsel Groups
Private (retained) counsel represented 71 defendants (37%). CJA panel attorneys, private lawyers appointed by the court, represented 48 (25%). Federal public or community defenders represented 45 (24%).
Retained counsel had a 94% plea rate and 3% dismissed. CJA panel attorneys had 85% and 10%. Defenders had 84% and 7%.
Defenders had 4 trials with 0 acquittals (0 of 4). CJA panel attorneys had 2 trials with 0 acquittals (0 of 2). Retained counsel had 2 trials, and 1 ended in an acquittal (1 of 2).
Defendants who hire lawyers and those with appointed lawyers face different charges and circumstances. The 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 | 45 | 84% | 7% | 4 | 0 (0 of 4) |
| CJA panel attorney | 48 | 85% | 10% | 2 | 0 (0 of 2) |
| Private (retained) counsel | 71 | 94% | 3% | 2 | 1 (1 of 2) |
What These Numbers Do Not Cover
The approved crosswalk lists no close court-martial counterpart for this statute. The records report outcomes and prison terms only. They do not describe the conduct charged or the reasons for any dismissal or verdict.
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 22 U.S.C. 2778, any subsection (191), 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)
- 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.