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18 U.S.C. § 1344

Section 1344 · Bank fraud

Amended 3 times on record

The circuits are split over this sectionWhether pretrial detention that is later credited as time served toward a sentence is imprisonment 'in connection with a conviction' that tolls the term of supervised release under 18 U.S.C. § 3624(e)

Applied in 2,793 court decisions — leading case Zedner v. United States (2006)

Most recently applied in United States v. Runner (July 2025)

Applied most in the Ninth Circuit Circuit (145 decisions)

Cases citing this section usually also cite 18 U.S.C. § 371 · 18 U.S.C. § 3553 · 28 U.S.C. § 1291

How often courts cite this section

198419902000201020202025169098-473enacted · 1984 · 98-473101-73amended · 1989 · 101-73amended · 1990 · 101-647Zedner v. United Statesleading · 2006 · Zedner v. United Statessplit · 2008 · circuit split
citing decisions per year

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.

Whoever knowingly executes, or attempts to execute, a scheme or artifice—

(1) to defraud a financial institution; or

(2) to obtain any of the moneys, funds, credits, assets, securities, or other property owned by, or under the custody or control of, a financial institution, by means of false or fraudulent pretenses, representations, or promises;

shall be fined not more than $1,000,000 or imprisoned not more than 30 years, or both.

Editorial notes U.S. Code · Office of the Law Revision Counsel

Amendments

1990—Pub. L. 101–647 substituted “30” for “20” before “years”.

1989—Pub. L. 101–73 amended section generally, restating former subsec. (a) and striking out former subsec. (b) which defined “federally chartered or insured financial institution”. Prior to amendment, subsec. (a) read as follows: “Whoever knowingly executes, or attempts to execute, a scheme or artifice—

“(1) to defraud a federally chartered or insured financial institution; or

“(2) to obtain any of the moneys, funds, credits, assets, securities or other property owned by or under the custody or control of a federally chartered or insured financial institution by means of false or fraudulent pretenses, representations, or promises, shall be fined not more than $10,000, or imprisoned not more than five years, or both.”

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