18 U.S.C. § 1168
Section 1168 · Theft by officers or employees of gaming establishments on Indian lands
This is § 23 of the Indian Gaming Regulatory Act of 1988
Amended 2 times on record
Applied in 8 court decisions — leading case Kaw Nation v. Springer (2003)
Most recently applied in Joe Daniel Holt, Jr. v. Robert M. Baker (October 2017)
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.
(a) Whoever, being an officer, employee, or individual licensee of a gaming establishment operated by or for or licensed by an Indian tribe pursuant to an ordinance or resolution approved by the National Indian Gaming Commission, embezzles, abstracts, purloins, willfully misapplies, or takes and carries away with intent to steal, any moneys, funds, assets, or other property of such establishment of a value of $1,000 or less shall be fined not more than $250,000 or imprisoned not more than five years, or both;
(b) Whoever, being an officer, employee, or individual licensee of a gaming establishment operated by or for or licensed by an Indian tribe pursuant to an ordinance or resolution approved by the National Indian Gaming Commission, embezzles, abstracts, purloins, willfully misapplies, or takes and carries away with intent to steal, any moneys, funds, assets, or other property of such establishment of a value in excess of $1,000 shall be fined not more than $1,000,000 or imprisoned for not more than twenty years, or both.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Amendments
1990—Subsec. (a). Pub. L. 101–647 substituted “or imprisoned” for “and be imprisoned for”.