49 U.S.C. 46314, Entering aircraft or airport area in violation of security requirements: How Federal Cases Ended, FY2016–2025
In fiscal years 2016 to 2025, 54 federal defendants had a most serious charge under 49 U.S.C. 46314 when their cases ended. The charge was a felony for 26 (48%) and a Class A misdemeanor for 28 (52%). Of the 50 convicted, 24 (48%) received a prison term on that charge, with a median of 11 months.
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In brief: In fiscal years 2016 to 2025, 54 federal defendants had a most serious charge under 49 U.S.C. 46314 when their cases ended. The charge was a felony for 26 (48%) and a Class A misdemeanor for 28 (52%). Of the 50 convicted, 24 (48%) received a prison term on that charge, with a median of 11 months.
This post uses the Federal Judicial Center's records of 54 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.
A Mix of Felony and Misdemeanor Charges
Charges under this section were close to evenly divided by level. Felonies made up 26 cases (48%), and Class A misdemeanors made up 28 (52%). There were no petty offenses.
The level recorded is the level of the most serious charge at the close of the case. The data does not say what conduct led to either level.
The Section Heading
Title 49, section 46314 of the U.S. Code has the heading "Entering aircraft or airport area in violation of security requirements." That heading is the only description of the section used in this post.
The Federal Judicial Center data includes every defendant whose case ended, counted as in the federal courts' Table D-4. Cases that ended in dismissal or acquittal are part of the 54.
Nearly All Pleaded Guilty
Guilty pleas ended 50 of the 54 cases (93%). Charges were dismissed for 3 defendants (6%). Only 1 defendant went to trial.
That single trial was decided by a judge without a jury, and it ended in an acquittal. One trial cannot support any acquittal rate.
In total, 50 of the 54 (93%) were convicted, all by guilty plea. Dismissed cases can include charges dropped on the government's motion, for example after a plea in another case.
How Many Received Prison Terms?
Among the 50 convicted, 24 (48%) received a prison term on this charge. The others had no prison term on this count.
The median term was 11 months, counting terms of 1 month or more. That figure is the middle of the ranked terms imposed. It does not reflect time served or the range of terms.
Lawyers Recorded at the End of the Case
Federal public or community defenders represented 23 defendants (43%). Retained private lawyers represented 17 (31%). CJA panel attorneys, who are private lawyers appointed by the court, represented 13 (24%). One defendant had no lawyer.
Every defendant with retained counsel or a CJA panel attorney pleaded guilty. In the federal defender group, 83% pleaded guilty and 13% had charges dismissed, and that group accounted for the 1 trial.
The counsel figures describe groups of cases and say nothing about the quality of lawyers. Hired and appointed lawyers can represent people facing different charges and circumstances, and these groups are small.
| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| Federal public or community defender | 23 | 83% | 13% | 1 | 1 (1 of 1) |
| CJA panel attorney | 13 | 100% | 0% | 0 | 0 |
| Private (retained) counsel | 17 | 100% | 0% | 0 | 0 |
| Self-represented | 1 | 1 of 1 | 0 of 1 | 0 | 0 |
Each Fiscal Year
No more than 9 cases ended in any fiscal year. The highest was 9 in fiscal year 2018, and the lowest was 2 in fiscal years 2020 and 2023. The yearly table lists each year and shows no trend.
| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
|---|---|---|---|---|---|
| 2016 | 8 | 8 of 8 | 0 of 8 | 0 | 0 |
| 2017 | 6 | 6 of 6 | 0 of 6 | 0 | 0 |
| 2018 | 9 | 9 of 9 | 0 of 9 | 0 | 0 |
| 2019 | 6 | 5 of 6 | 0 of 6 | 1 | 1 (1 of 1) |
| 2020 | 2 | 2 of 2 | 0 of 2 | 0 | 0 |
| 2021 | 3 | 3 of 3 | 0 of 3 | 0 | 0 |
| 2022 | 4 | 3 of 4 | 1 of 4 | 0 | 0 |
| 2023 | 2 | 2 of 2 | 0 of 2 | 0 | 0 |
| 2024 | 8 | 7 of 8 | 1 of 8 | 0 | 0 |
| 2025 | 6 | 5 of 6 | 1 of 6 | 0 | 0 |
What Cannot Be Known From These Records
The records give no case facts and no reasons for any plea, dismissal, or sentence. With no close court-martial counterpart in the approved crosswalk, the post reports federal numbers 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 49 U.S.C. 46314, any subsection (54), 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)
- 49 U.S.C. 46504, Interference with flight crew members and attendants: How Federal Cases Ended, FY2016–2025 (same title of the U.S. Code)
- 49 U.S.C. 46506, Application of certain criminal laws to acts on aircraft: 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.