18 U.S.C. § 2114

Mail, money, or other property of United States

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(a)Assault.—A person who assaults any person having lawful charge, control, or custody of any mail matter or of any money or other property of the United States, with intent to rob, steal, or purloin such mail matter, money, or other property of the United States, or robs or attempts to rob any such person of mail matter, or of any money, or other property of the United States, shall, for the first offense, be imprisoned not more than ten years; and if in effecting or attempting to effect such robbery he wounds the person having custody of such mail, money, or other property of the United States, or puts his life in jeopardy by the use of a dangerous weapon, or for a subsequent offense, shall be imprisoned not more than twenty-five years.(b)Receipt, Possession, Concealment, or Disposal of Property.—A person who receives, possesses, conceals, or disposes of any money or other property that has been obtained in violation of this section, knowing the same to have been unlawfully obtained, shall be imprisoned not more than 10 years, fined under this title, or both.(June 25, 1948, ch. 645, 62 Stat. 797; Pub. L. 98–473, title II, § 223(d), Oct. 12, 1984, 98 Stat. 2028; Pub. L. 101–647, title XXXV, § 3562, Nov. 29, 1990, 104 Stat. 4927; Pub. L. 103–322, title XXXII, §§ 320602, 320903(a)(3), Sept. 13, 1994, 108 Stat. 2115, 2124; Pub. L. 104–294, title VI, § 604(b)(17), Oct. 11, 1996, 110 Stat. 3507.)Historical and Revision Notes

Based on title 18, U.S.C., 1940 ed., § 320 (Mar. 4, 1909, ch. 321, § 197, 35 Stat. 1126; Aug. 26, 1935, ch. 694, 49 Stat. 867).

The attention of Congress is directed to the mandatory minimum punishment provisions of sections 2113(e) and 2114 of this title. These were left unchanged because of the controversial question involved. Such legislative attempts to control the discretion of the sentencing judge are contrary to the opinions of experienced criminologists and criminal law experts. They are calculated to work manifest injustice in many cases.

Minor changes were made in phraseology.

Editorial NotesAmendments

1996—Pub. L. 104–294 amended Pub. L. 103–322, § 320602. See 1994 Amendment note below.

1994—Pub. L. 103–322, § 320903(a)(3), inserted “or attempts to rob” after “robs” in subsec. (a).

Pub. L. 103–322, § 320602, as amended by Pub. L. 104–294, § 604(b)(17), designated existing provisions as subsec. (a), inserted heading, substituted “A person who” for “Whoever”, and added subsec. (b).

1990—Pub. L. 101–647 inserted a comma after “money” in section catchline.

1984—Pub. L. 98–473, which directed insertion of “not more than” after “imprisoned”, was executed by making the insertion after “imprisoned” the second time appearing.

Statutory Notes and Related SubsidiariesEffective Date of 1996 Amendment

Amendment by Pub. L. 104–294 effective Sept. 13, 1994, see section 604(d) of Pub. L. 104–294, set out as a note under section 13 of this title.

Effective Date of 1984 Amendment

Amendment by Pub. L. 98–473 effective Nov. 1, 1987, and applicable only to offenses committed after the taking effect of such amendment, see section 235(a)(1) of Pub. L. 98–473, set out as an Effective Date note under section 3551 of this title.

Notes of Decisions

Cited in 430 cases (42 in the last 5 years), 1951–2026 · leading case: United States v. Terron Bryant, 949 F.3d 168 (4th Cir. 2020).

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United States v. Terron Bryant, 949 F.3d 168 (4th Cir. 2020). · cites it 9× “FLOYD, Circuit Judge: In 2010, Terron Lamar Bryant was convicted for assaulting with intent to rob, steal, or purloin a postal employee and placing their life in jeopardy by use of a dangerous weapon, in violation of 18 U.S.C. § 2114 (a), and for brandishing a firearm during and…”

Michael Knight v. United States, 936 F.3d 495 (6th Cir. 2019). · cites it 10× “The government maintains, however, that Knight’s conviction under § 924(c) for using a firearm during assault and robbery in violation of 18 U.S.C. § 2114 (a) should be affirmed because that offense qualifies under the “elements clause” of the definition of a “crime of violence”…”

United States v. Deandre Enoch, 865 F.3d 575 (7th Cir. 2017). · cites it 10× “The government charged Deandre Enoch with robbing a person having custody of property belonging to the United States, under 18 U.S.C. § 2114 (a) and brandishing a firearm in relation to a crime of violence, under 18 U.”

Garcia v. United States, 469 U.S. 70 (1985). · cites it 6× “They were convicted of violating 18 U. S. C. § 2114 , which proscribes the assault and robbery of any custodian of "mail matter or of any money or other property of the United States.”

USA V.tony Buck, 23 F.4th 919 (9th Cir. 2022). · cites it 8× “§ 2255 in which federal prisoner Tony Buck argued that his convictions for assaulting a mail carrier with intent to steal in violation of 18 U.S.C. § 2114 (a) did not qualify as crimes of violence under 18 U.”

United States v. Ricardo Ruiz & Tyrone Michael Crawford, 986 F.2d 905 (5th Cir. 1993). · cites it 9× “Ruiz and Crawford were charged in a three-count indictment that stated: (1) Ruiz and Crawford assaulted a person having charge of money and other property of the United States with the intent to rob, and in so doing put the life of the victim in jeopardy by the use of a…”

United States v. Robert Earl Dowd, 451 F.3d 1244 (11th Cir. 2006). · cites it 4× “8 Dowd also received a consecutive seven-year sentence for his Count Two conviction for using a handgun in the commission of a crime of violence, in violation of 18 U.S.C. § 924 (c).”

United States v. Troy Vaval, AKA Just. Vaval, 404 F.3d 144 (2d Cir. 2005). · cites it 3× “§ 2119 (1) (Count I), robbery of federal money using a dangerous weapon, 18 U.S.C. § 2114 (a) (Count II), and possession of a firearm with an obliterated serial number, 18 U.”

United States v. Walter B. Spears, 449 F.2d 946 (D.C. Cir. 1971). · cites it 14× “Thus, both 18 U.S.C. § 2114 and D.C.Code §§ 22-2901, 3202 each are applicable to the crime committed by appellant, 12 and since we vacate the conviction on the assault charge, the fact that it was charged under the federal law, while the robbery was charged under the District…”

United States v. George E. Moore (88-5932) & Charles R. Morse, (88-5942), 917 F.2d 215 (6th Cir. 1990). · cites it 4× “Moore argues the district court erred by failing to set forth all of the necessary elements required to prove the offense of armed post office robbery pursuant to 18 U.S.C. § 2114 . At the time of the offense, 18 U.”

United States v. Taylor, 848 F.3d 476 (1st Cir. 2017). · cites it 2× “§§ 111 (a)(1) and (b), (3) robbery and attempted robbery under 18 U.S.C. § 2114 (a), (4) kidnapping under 18 U.”

Graham Cnty. Soil & Water Conservation Dist. v. United States Ex Rel. Wilson, 559 U.S. 280 (2010). · cites it 2× “are each separated by the conjunction ‘or’ ” (quoting 18 U. S. C. §2114 ; some emphasis deleted)).”

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— 18 U.S.C. § 2114(a) — 2 cases

Forteza-Garcia v. United States (D.P.R. 2021).

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