Austrian police intercepted the van, and after breaking through the welded doors, were able to rescue 26 refugees, including three young children who were close to death from dehydration.
The migrants were originally from Syria, Bangladesh and Afghanistan.
The court said the driver, aged 30, could not appeal against his sentence.
The police had stopped his Romanian-registered vehicle after a chase near the Austrian town of St. Peter am Hart in Upper Austria, on the border with Germany.
The incident occurred just two days after Austrian police found the decomposing bodies of 71 migrants in an abandoned truck on a motorway in Burgenland, which had been abandoned after crossing from Hungary.