18 U.S.C. § 1694
Section 1694 · Carriage of matter out of mail over post routes
Amended 2 times on record
Applied in 8 court decisions — leading case Regents of University of California v. Public Employment Relations Board (1988)
Most recently applied in Knox v. Brnovich (October 2018)
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.
Whoever, having charge or control of any conveyance operating by land, air, or water, which regularly performs trips at stated periods on any post route, or from one place to another between which the mail is regularly carried, carries, otherwise than in the mail, any letters or packets, except such as relate to some part of the cargo of such conveyance, or to the current business of the carrier, or to some article carried at the same time by the same conveyance, shall, except as otherwise provided by law, be fined under this title.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
Based on title 18, U.S.C., 1940 ed., §307 (Mar. 4, 1909, ch. 321, §184, 35 Stat. 1124).
Words “by land, air, or water” were substituted for “stagecoach, railway car, steamboat” with necessary minor changes in phraseology.
Enumeration of persons having charge was omitted as unnecessary.
Amendments
1994—Pub. L. 103–322 substituted “fined under this title” for “fined not more than $50”.
Study of Private Carriage of Mail; Reports to President and Congress
Congressional findings of need for study and reevaluation of restrictions on private carriage of letters and packets contained in this section and submission by United States Postal Service of reports to President and Congress for modernization of law, regulations, and administrative practices, see section 7 of Pub. L. 91–375, set out as a note under section 601 of Title 39, Postal Service.