1 U.S.C. § 4
Section 4 · Vehicle as including all means of land transportation
Amended 1 time on record
Applied in 23 court decisions — leading case United States v. McGlamory (1971)
Most recently applied in United States v. Gerald Wheeler (March 2025)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
The word “vehicle” includes every description of carriage or other artificial contrivance used, or capable of being used, as a means of transportation on land.