18 U.S.C. § 23
Section 23 · Court of the United States defined
This is § 320914 of the Violent Crime Control and Law Enforcement Act of 1994
Amended 1 time on record
Applied in 14 court decisions — leading case Free Enterprise Fund v. Public Company Accounting Oversight Bd. (2010)
Most recently applied in United States v. Freeman (April 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.
As used in this title, except where otherwise expressly provided 2 the term “court of the United States” includes the District Court of Guam, the District Court for the Northern Mariana Islands, and the District Court of the Virgin Islands.
2 So in original. Probably should be followed by a comma.