Editor’s Note: By its very nature, there are no other crimes that come with more finality than murder. We’ve been trained by decades of Hollywood movies and TV dramas to believe that all crime may be local but all major crimes are federal. However, a review of murder prosecutions quickly dispels that myth. In this week’s The Rabbit Hole, reporter Peter Beck walks us through the various federal statutes that are available to prosecute capital offenses and explains why using them is exceedingly rare. -Seamus
A 21-year-old cold case on a U.S. Army base in Germany. The fatal shooting of a lover by an aspiring OnlyFans model in a national park. And a 16-year-old strangling their step-sister on a Carnival Cruise line. These are a few among the handful of federal murder cases each year.
In March, FBI Director Kash Patel posted on X a chart showing the sharp decline in the U.S. homicide rate since 2020. Patel captioned the post with “Leadership matters.” Commentators online quickly pointed out that the latest spike in homicide rates, coinciding with the onset of the pandemic in 2020, occurred during President Trump’s first term, and that the declining homicide rate had begun under President Biden.
Somewhere lost in the political tit-for-tat was the remarkable fact that the homicide rate in the United States has plummeted to a century low. In a nation full of weapons, with its own unique set of circumstances in which crimes occur, and that frequently appears to teeter on the edge of political chaos, people in the U.S. managed to exercise greater self-restraint and remain peaceful toward their neighbors.
The federal government undoubtedly had a role to play: through grants for gun violence interdiction initiatives, targeting criminal networks that span across states, supporting local investigations through state-of-the-art forensic facilities, and interagency cooperation with state authorities. But the FBI and the Department of Justice seldom pursue murder cases entirely themselves.
The overwhelming majority of homicide cases—the killing of a person by another—are handled at the state level through murder and manslaughter investigations. One researcher counted just 75 murder-related cases at the federal level in 2014, compared to the total number of 14,249 murders in the U.S. that year. That puts the rate of murder cases that federal prosecutors handle at just a little more than half a percent.
Under the Constitution’s federalist framework, states have the “police power,” meaning that federal officials lack the jurisdiction to investigate crimes that do not involve a federal nexus. But for the murders that do involve the federal government, their allegations are often the most audacious and consequential, involving terrorism, assassinations of federal officials, transnational cartel violence, federal property, and killings that cross state lines.
Federal prosecutors primarily use six statutes to pursue murder charges that rise to the level of federal interest. The first of these statutes, 18 U.S.C. § 1111, has to do with federal land itself, prohibiting murder within the “special maritime and territorial jurisdiction of the United States.” One of the places that falls under this “special” jurisdiction is national parks.
Chelsea Perkins and Matthew Dunmire had a fraught relationship. By May 2021, according to federal prosecutors, the two had known each other for years. In 2017, Perkins accused Dunmire of rape, and in February 2021, she messaged a friend on Facebook, “How… does he live with himself?” and “he will get his someday.” The friend’s response, which was later revealed in federal court, stated, “Karma is an evil bitch.”
A few weeks later, the two became friends on Facebook on March 2, 2021. In the next few days, Dunmire signed up as a paid subscriber to view Perkins’ OnlyFans page. He also visited other adult content sites to look at additional media of her.
On March 5, 2021, Dunmire met a group of coworkers at a bar called the Tiki Underground in Cuyahoga Falls, Ohio, where he told them that a woman was coming to pick him up to film “OnlyFans content” in a graveyard in the woods nearby. Prosecutors’ filings characterized Perkins as having an unusual, morbid attraction to cemeteries. In separate messages to friends on Facebook, she allegedly wrote, “I like the cemetery at the end of the street where Banks St. Bar is. Once I snuck into St. Louis Cemetery at night climbing up the wall but that’s prob super illegal.” She also posted about wanting to “do a NSFW shoot at the Arlington Cemetery.”
Perkins left her husband and two kids at their home in Arlington, Virginia, and drove to meet Dunmire at the Tikki Underground that night. The two went to an Airbnb near Cleveland that Perkins had reserved for the night and created content for Perkins’ OnlyFans and Twitter. She also reportedly messaged a tattoo artist in Michigan, whom she had an appointment with the next day.
At 9:30 the next morning, Dunmire and Perkins climbed into her car and left their Airbnb for the Cuyahoga Valley National Park. They started hiking toward a cemetery in the park but wandered off the established trail path. After hiking for more than two hours, deep into the woods, Perkins held a 9mm pistol to the back of Dunmire’s head and fired.
Perkins then left the park, unfriended Dunmire on Facebook, and texted the tattoo artist that she was on the way. She reached Michigan and texted her husband a picture of her new tattoo, writing, “I had the best day!”
Hikers discovered Dunmire’s body three days later. Perkins' new tattoo was of a noose. She was arrested in December 2021. Almost four years later, a judge sentenced her to 22 years in federal prison for committing a murder in a special jurisdiction of the U.S. Her mental health history was redacted in federal court records but appears to have been a mitigating factor in the case.
The other locations that qualify under the federal government’s “special” jurisdiction include federal properties, military bases, the high seas, and aircraft. The federal connection to government properties and military bases makes sense: the federal government should be able to investigate crimes that quite literally happen on its land. In 2024, a former U.S. Army soldier was sentenced to 30 years in prison for the 2001 killing of a 19-year-old fellow soldier, who was pregnant at the time. A separate law, the Military Extraterritorial Jurisdiction Act, allows prosecutors to charge crimes that allegedly happened at military installations outside the United States.
The more perplexing cases are the deaths that occurred on an aircraft or on the high seas. Given how planes and vessels frequently traverse state borders, federal officials regulate maritime operations and air travel. The fact patterns of these cases are often bizarre.
Although cases of mid-flight assaults and interfering with air travel are more common, murders that happen on airplanes are exceedingly rare and usually involve the hijacking or bombing of the plane, which implicates separate statutes than § 1111’s “special” jurisdiction. A query by Court Watch could not find any § 1111 cases involving airplanes.
The maritime jurisdiction, however, is much more commonly used because of the U.S.’s major role in global maritime trade and its cruise industry. In 2018, a Mexican man killed a crew member and attacked two others with a shucking hammer and a long fishing knife on a scalloping vessel 55 miles off the coast of Nantucket. After the struggle, prosecutors say the man climbed to the top of the fishing vessel with the hammer and refused to come down until the Coast Guard arrived and took him into custody. He was later sentenced to roughly 20 years in prison.
More recently, in April, a grand jury in the Southern District of Florida indicted a 16-year-old as an adult for the alleged murder and sexual abuse of his teenage stepsister on a Carnival cruise ship. The two reportedly shared a cabin aboard the 4,000-passenger ship sailing to the Caribbean and Mexico. A judge ordered that the 16-year-old be detained until his trial.
The second statute giving federal prosecutors the ability to charge murder cases is an area that is traditionally located within states, but falls beyond their usual authorities: Native Americans living on tribal lands. In the 1883 case Ex Parte Crow Dog, the Supreme Court unanimously threw out the murder conviction of a Native American man who had killed another tribal member on the Great Sioux Reservation in South Dakota, holding that Congress had not given federal courts the jurisdiction to adjudicate cases involving crimes perpetrated by a Native American against another.
Congress reacted to the decision by enacting the Major Crimes Act (18 U.S.C. § 1153) in 1885, giving federal courts the jurisdiction to hear cases of Native Americans accused of committing murder, manslaughter, kidnapping, sexual assault, incest, and felony assault on tribal land. Beyond the Major Crimes Act, tribal courts handle lower-level cases carrying less than a year in prison and are allegedly committed by Native Americans. Tribal courts, on the other hand, lack jurisdiction over non-Native Americans. Crimes on reservations committed by non-Native Americans are primarily handled by state authorities, with major cases involving Native Americans referred for federal prosecution. In 2022, the Supreme Court held in Oklahoma v. Castro-Huerta that states can prosecute non-Native Americans for crimes in which Native Americans are the victims.
The complicated jurisdictional setup contributes to the small pool of federal murder prosecutions. Two Native Americans who were separately members of the Zuni Pueblo and Navajo Nations were federally charged in 2022 for murder and kidnapping on tribal lands. One of them, Kendra Panteah, was on a road trip through Mexico and Arizona with a group when an altercation began that ended with one of the passengers being beaten and placed in the trunk of their car.
Panteah then drove to the house of the other man charged with the murder, Gilbert John, on the Navajo Nation’s reservation. John drove the car around for another day, stabbed the man inside the trunk, drove it into a canyon, and then set the car on fire. Panteah pleaded guilty to kidnapping and was sentenced to 18 years, while John pleaded guilty under the Major Crimes Act to murder and was sentenced to 21 years in prison.
In September 2025, a federal judge sentenced a member of the Osage Nation to 30 years in prison for the murder of a non-Native American woman in Oklahoma. Prosecutors stated the man had arranged to meet up with the woman near Tulsa to pay for sex, and that he admitted to shooting at her in order to scare her after she refused to have sex with him because he did not bring enough money. In McGirt v. Oklahoma (2020), the Supreme Court reaffirmed the Major Crimes Act and that Native Americans can only face charges in federal courts for crimes committed on tribal reservations rather than state courts.
Several of the other federal statutes for murder cover offenses that are interstate in nature. 18 U.S.C. § 1958, the statute for murder-for-hire using interstate commerce facilities, is perhaps the most notorious for its sinister tales of hitmen traveling hundreds of miles to target embittered paramours or mob bosses. In November 2021, a Nashville-based grand jury indicted Erik Maund, the scion of an Austin car dealership empire, and three other men for a murder-for-hire plot that left two people dead.
Prosecutors said it all began when Maund, who was married, had an affair with a woman named Holly Williams. According to federal court records, Maund would travel from Austin to Nashville to stay at hotels with Williams. But she also had another lover—William Lanway, who found out about the duo’s rendezvous. Rather than simply cutting things off with Williams, Lanway told Maund that he knew about the affair and demanded that Maund pay him off, or else he would tell his family.
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Instead of just paying the ransom, Maund contacted Gilad Peled, the owner of a private security company based in Austin, who advertised his expertise as a former member of the Israeli Defense Forces and Mossad. The men then allegedly concocted a plan with the help of four other private security contractors to spy on Williams and Lanway. But the plan soon shifted to kidnapping the couple from their apartment complex in Nashville, and then to murdering them. Two of the hitmen shot Williams and Lanway execution style, discarding their bodies at a construction site. Maund had paid over a million dollars for the hit.
Maund, Peled, and the other hitmen were charged 20 months later. In November 2023, Maund was convicted of murder-for-hire after an almost three-week jury trial in Nashville. A judge later granted his defense attorney’s motion for a new trial after it came to light that unadmitted exhibits were inadvertently sent to the jury during its deliberations. The U.S. Court of Appeals for the Sixth Circuit, however, held that the error did not structurally influence the jury’s deliberations and reinstated the conviction in February 2026.
Two other federal murder statutes trace back to the Reconstruction Era and the Thirteenth and Fourteenth amendments: 18 U.S.C. § 249, a hate crime resulting in death, and 18 U.S.C. § 242, deprivation of civil rights under color of law, resulting in death. The legal theory behind these acts was that the Reconstruction-era amendments empowered Congress to pass legislation guaranteeing that people’s civil rights and lives would be protected, regardless of their group identity.
Under Section 2 of the Thirteenth Amendment’s ban on “badges and incidents of slavery,” federal prosecutors have the authority to file § 249 charges for murders allegedly motivated by race, ethnicity, religion, and national origin without an interstate jurisdictional hook. However, for other protected categories, such as gender, sexual orientation, gender identity, and disability, federal prosecutors have to tie the alleged murder to activities crossing state lines in order to invoke the Constitution’s Commerce Clause, which Congress often uses to justify federal intervention.
The Department of Justice has used § 249 to pursue federal hate crime cases against some of the U.S.’s deadliest extremists. In 2017, Dylann Roof, who massacred nine parishioners at a historic Black church in Charleston, South Carolina, was sentenced to death after being convicted of § 249. The antisemitic shooter who attacked Pittsburgh’s Tree of Life Synagogue in 2018 was also convicted and sentenced to death under § 249. The men are two of the remaining three members on federal death row—besides Boston bomber Dzhokhar Tsarnaev—after President Biden commuted other members’ sentences. Patrick Crusius, who killed 23 people in a hate-fueled rampage at a Walmart in Texas in 2019, agreed to plead guilty to § 249 in exchange for prosecutors not seeking the death penalty.
As with § 249’s civil rights history, the statute for the deprivation of civil rights resulting in death while under the cover of law, § 242, was enacted to hold government officials criminally accountable when they used the power of their office to violate someone’s constitutional rights, closing a gap left by state systems that wouldn’t, or couldn’t, police their own. Today’s Justice Department rarely charges it. In March, however, a jury convicted a former San Diego Sheriff’s Deputy of § 242 for fatally shooting a 36-year-old unarmed man in the back four times as he ran away from law enforcement in 2020. A judge sentenced the former deputy to 12 years in prison.
Derek Chauvin, the Minneapolis police officer who killed George Floyd, was also charged with § 242. He ultimately pleaded guilty and was sentenced in 2022 to more than 21 years in prison, which he will serve simultaneously with his state sentence of 22.5 years for murder.
Finally, the last of the statutes that federal prosecutors can use to file murder charges has to do with the victims themselves. The president, members of Congress, federal officials, and foreign diplomats all have statutes that federal officials can use to prosecute their assassins. Yet the statute that prohibits the killing of a president, 18 U.S.C. § 1751, has never been used to charge a successful assassin. Enacted in the wake of President John F. Kennedy’s death, the Department of Justice has charged it against attempted assassins who targeted presidents Gerald Ford, Ronald Reagan, and Donald Trump.
In May 2025, federal prosecutors charged Elias Rodriguez with 18 U.S.C. § 1116, the murder of a foreign official, and § 249, the hate crimes statute. Rodriguez allegedly killed two diplomats stationed at the Israeli embassy in Washington, D.C., as they left the Capital Jewish Museum. Prosecutors said he stated, “I did it for Palestine. I did it for Gaza,” after the murders. On May 15, prosecutors formally notified the U.S. District Court for the District of Columbia and Rodriguez’s defense attorneys that they plan to seek the death penalty. If it goes to trial, the case will mark a significant test of the Justice Department’s ability to pursue capital murder cases, especially in a jurisdiction where just 40 percent of residents support the death penalty, the lowest level of support nationwide.
Pop culture often glorifies the role of federal law enforcement in investigating violent crimes past the point of reality. The television show Criminal Minds depicts a squad of roving federal investigators who seemingly have jurisdiction wherever they go. The Silence of the Lambs features an FBI agent on the hunt for a serial killer. CBS has three whole series dramatizing the FBI by the mega producer Dick Wolf.
But the truth is that murder prosecutions are few and far between at the federal level. When they do happen, it’s because of a narrow, limiting set of circumstances. These cases are also revealing for their differences from state murder prosecutions: Federal cases usually involve greater resources at both the prosecution’s and defense’s disposal and tend to end in more lenient prison sentences for the defendant. While incarcerated, these defendants also tend to have access to greater rehabilitation programs and education resources than people serving convictions in state prisons.
The dramatization and hyperfocus on federal law enforcement also come at a cost. Efforts to increase funding for more violent crime investigations may be misplaced at the federal level. Initiatives to reform the justice system, such as lowering automatic sentences, shouldn’t focus their political capital at the federal level, where just roughly 10 percent of prisoners are incarcerated.
So on this lazy Sunday morning, we’ll grant you the joy of escapism that comes with watching your favorite TV FBI agent arrest a serial killer they’ve been tracking for years or the intense dramatic closing arguments of a federal prosecutor in a Hollywood movie convincing a jury to convict a wanton murderer. Just grant us this truism that it’s largely divorced from the history and realities of our criminal justice system.
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