18 U.S.C. § 2234
Section 2234 · Authority exceeded in executing warrant
Amended 3 times on record
Applied in 11 court decisions — leading case Simpson v. United States (1965)
Most recently applied in Rodriguez v. Swartz (August 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, in executing a search warrant, willfully exceeds his authority or exercises it with unnecessary severity, shall be fined under this title or imprisoned not more than one year, or both.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
Based on title 18, U.S.C., 1940 ed., §631 (June 15, 1917, ch. 30, title XI, §21, 40 Stat. 230).
Minor changes were made in phraseology.
Amendments
2002—Pub. L. 107–273 inserted “, or both” after “year”.
1996—Pub. L. 104–294 substituted “fined under this title” for “fined not more than $1,000”.