18 U.S.C. § 21
Section 21 · Stolen or counterfeit nature of property for certain crimes defined
This is § 320910 of the Violent Crime Control and Law Enforcement Act of 1994
Amended 1 time on record
Applied in 16 court decisions — leading case United States v. Gottfried (1948)
Most recently applied in United States of America v. P Joshua Fields (July 2023)
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) Wherever in this title it is an element of an offense that—
(1) any property was embezzled, robbed, stolen, converted, taken, altered, counterfeited, falsely made, forged, or obliterated; and
(2) the defendant knew that the property was of such character;
such element may be established by proof that the defendant, after or as a result of an official representation as to the nature of the property, believed the property to be embezzled, robbed, stolen, converted, taken, altered, counterfeited, falsely made, forged, or obliterated.
(b) For purposes of this section, the term “official representation” means any representation made by a Federal law enforcement officer (as defined in section 115) or by another person at the direction or with the approval of such an officer.