18 U.S.C. § 1581
Section 1581 · Peonage; obstructing enforcement
Amended 4 times on record
Applied in 67 court decisions — leading case Flood v. Kuhn (1972)
Most recently applied in Keo Ratha v. Rubicon Resources, LLC (July 2024)
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 holds or returns any person to a condition of peonage, or arrests any person with the intent of placing him in or returning him to a condition of peonage, shall be fined under this title or imprisoned not more than 20 years, or both. If death results from the violation of this section, or if the violation includes kidnapping or an attempt to kidnap, aggravated sexual abuse or the attempt to commit aggravated sexual abuse, or an attempt to kill, the defendant shall be fined under this title or imprisoned for any term of years or life, or both.
(b) Whoever obstructs, or attempts to obstruct, or in any way interferes with or prevents the enforcement of this section, shall be liable to the penalties prescribed in subsection (a).
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
Based on title 18, U.S.C., 1940 ed., §§444, 445 (Mar. 4, 1909, ch. 321, §§269, 270, 35 Stat. 1142).
Section consolidates sections 444 and 445 of said title 18, U.S.C., 1940 ed., with changes in phraseology to amplify and clarify their provisions.
Reference to persons causing or procuring was omitted as unnecessary in view of definition of “principal” in section 2 of this title.
Amendments
2000—Subsec. (a). Pub. L. 106–386 substituted “20 years” for “10 years” and inserted at end “If death results from the violation of this section, or if the violation includes kidnapping or an attempt to kidnap, aggravated sexual abuse or the attempt to commit aggravated sexual abuse, or an attempt to kill, the defendant shall be fined under this title or imprisoned for any term of years or life, or both.”
1996—Subsec. (a). Pub. L. 104–208 substituted “10 years” for “five years”.
1994—Subsec. (a). Pub. L. 103–322 substituted “fined under this title” for “fined not more than $5,000”.
Effective Date of 1996 Amendment
Section 218(d) of div. C of Pub. L. 104–208 provided that: “This section [amending this section and sections 1583, 1584, and 1588 of this title and enacting provisions set out as notes under section 994 of Title 28, Judiciary and Judicial Procedure] and the amendments made by this section shall apply with respect to offenses occurring on or after the date of the enactment of this Act [Sept. 30, 1996].”