18 U.S.C. § 231

Civil disorders

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(a)(1) Whoever teaches or demonstrates to any other person the use, application, or making of any firearm or explosive or incendiary device, or technique capable of causing injury or death to persons, knowing or having reason to know or intending that the same will be unlawfully employed for use in, or in furtherance of, a civil disorder which may in any way or degree obstruct, delay, or adversely affect commerce or the movement of any article or commodity in commerce or the conduct or performance of any federally protected function; or(2) Whoever transports or manufactures for transportation in commerce any firearm, or explosive or incendiary device, knowing or having reason to know or intending that the same will be used unlawfully in furtherance of a civil disorder; or(3) Whoever commits or attempts to commit any act to obstruct, impede, or interfere with any fireman or law enforcement officer lawfully engaged in the lawful performance of his official duties incident to and during the commission of a civil disorder which in any way or degree obstructs, delays, or adversely affects commerce or the movement of any article or commodity in commerce or the conduct or performance of any federally protected function—

Shall be fined under this title or imprisoned not more than five years, or both.

(b) Nothing contained in this section shall make unlawful any act of any law enforcement officer which is performed in the lawful performance of his official duties.(Added Pub. L. 90–284, title X, § 1002(a), Apr. 11, 1968, 82 Stat. 90; amended Pub. L. 103–322, title XXXIII, § 330016(1)(L), Sept. 13, 1994, 108 Stat. 2147.)Editorial NotesAmendments

1994—Subsec. (a). Pub. L. 103–322 substituted “fined under this title” for “fined not more than $10,000” in concluding par.

Statutory Notes and Related SubsidiariesShort Title

Pub. L. 90–284, title X, § 1001, Apr. 11, 1968, 82 Stat. 90, provided that: “This title [enacting this chapter] may be cited as the ‘Civil Obedience Act of 1968’.”

Notes of Decisions
Cited in 202 cases (108 in the last 5 years), 1928–2026 · leading case: United States v. Red Feather, 392 F. Supp. 916 (D.S.D. 1975).
United States v. Red Feather, 392 F. Supp. 916 (D.S.D. 1975). · cites it 15× “Each of the defendants is charged by indictment with violating 18 U.S.C. § 231 (a)(3) which provides: Whoever commits or attempts to commit any act to obstruct, impede, or interfere with any fireman or law enforcement officer lawfully engaged in the lawful performance of his…”
Branzburg v. Hayes, 408 U.S. 665 (1972). · cites it 4× “*677 § 1751 (assassination, attempts to assassinate, conspiracy to assassinate the President), 18 U. S. C. § 231 (civil disorders), 18 U.”
United States v. Saffo, 227 F.3d 1260 (10th Cir. 2000). · cites it 4× “§ 922 (d) (selling or otherwise disposing of any firearm or ammunition to any person “knowing or having reasonable cause to believe” that such person meets one of nine criteria); 18 U.S.C. § 231 (a)(1) (teaching or demonstrating to another the use, application, or making of any…”
United States v. Tia Deyon Pugh, 90 F.4th 1318 (11th Cir. 2024). · cites it 6× “BRASHER, Circuit Judge: This appeal raises questions of first impression about the constitutionality of 18 U.S.C. § 231 (a)(3), which prohibits impeding law enforcement officers during a civil disorder affecting interstate commerce.”
United States v. Dodge, 538 F.2d 770 (8th Cir. 1976). · cites it 8× “, appeal from an unreported decision of Judge Urbom convicting them of conspiracy to obstruct, impede or interfere with law enforcement officers, in violation of 18 U.S.C. §§ 231 (a)(3) and 371. In No. 75-1398, Bernard Bravo Escamilla appeals from his conviction by a jury of the…”
United States v. Huff, 630 F. App'x 471 (6th Cir. 2015). · cites it 7× “Defendant Darren Wesley Huff was convicted in federal district court of transporting a firearm in commerce with the intent that it be used unlawfully in furtherance of a civil disorder, in violation of 18 U.S.C. § 231 (a)(2). He was sentenced to forty-eight months of…”
United States v. Thomas Cameron Kincade, 379 F.3d 813 (9th Cir. 2004). “§ 2231 ; various forms of “civil disorder,” 18 U.S.C. § 231 ; participation, promotion, or incitement of a riot, 18 U.”
The Black Panther Party v. William French Smith, Attorney Gen. of the United States, 661 F.2d 1243 (D.C. Cir. 1981). · cites it 2× “§ 371 , by unlawful intimidation, force, violence, terrorist activities and inducements to kidnapping, murder and interference with law enforcement officers in the lawful performance of their official duties. For example, see Interrogatories 80 (storing guns and military…”
United States v. McArthur, 419 F. Supp. 186 (D.N.D. 1976). · cites it 3× “1 *190 The indictments are under 18 U.S.C. § 231 (a)(3), which states: “Whoever commits or attempts to commit any act to obstruct, impede, or interfere with any fireman or law enforcement officer lawfully engaged in the lawful performance of his official duties incident to and…”
United States v. Marcus Walker, 990 F.3d 316 (3rd Cir. 2021). “In Carpenter, the Court 5 The District Court had jurisdiction under 18 U.S.C. § 231 . We have jurisdiction under 28 U.”
United States v. Warnagiris (D.D.C. 2025). · cites it 202× “§ 5104 (e)(2)(G) 36 months’ probation 12 months’ probation $500 restitution $500 restitution Colon, Luis 1:21-CR-160-TJK 18 U.S.C. § 231 (a)(3) 24 months’ probation 24 months’ probation Enrique $2,000 restitution $2,000 restitution 1 Early in this investigation, the Government…”
United States v. David T. Dellinger, 472 F.2d 340 (7th Cir. 1973). · cites it 2× “the indictment charged that defendants and others conspired not only to travel in and use the facilities of interstate commerce with the intent to incite, organize, promote and encourage a riot, but also to participate in and carry on a riot, to commit acts of violence in…”
— 18 U.S.C. § 231(a) — 3 cases
United States v. Lee (D.D.C. 2024).
— 18 U.S.C. § 231(a)(1) — 1 case
United States v. Sargent (D.D.C. 2022).
— 18 U.S.C. § 231(a)(3) — 3 cases
United States v. Red Feather, 392 F. Supp. 916 (D.S.D. 1975). “Each of the defendants is charged by indictment with violating 18 U.S.C. § 231 (a)(3) which provides: Whoever commits or attempts to commit any act to obstruct, impede, or interfere with any fireman or law enforcement officer lawfully engaged in the lawful performance of his…”
United States v. Warnagiris (D.D.C. 2025). “§ 5104 (e)(2)(G) 36 months’ probation 12 months’ probation $500 restitution $500 restitution Colon, Luis 1:21-CR-160-TJK 18 U.S.C. § 231 (a)(3) 24 months’ probation 24 months’ probation Enrique $2,000 restitution $2,000 restitution 1 Early in this investigation, the Government…”
United States v. Bray (D.D.C. 2024).
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