18 U.S.C. § 291
Section 291 · Purchase of claims for fees by court officials
Amended 4 times on record
Applied in 5 court decisions — leading case Mendez v. Belton (1984)
Most recently applied in In re Biaggi (April 1989)
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, being a judge, clerk, or deputy clerk of any court of the United States or a Territory or Possession thereof, or a United States district attorney, assistant attorney, marshal, deputy marshal, commissioner, or other person holding any office or employment, or position of trust or profit under the United States, directly or indirectly purchases at less than the full face value thereof, any claim against the United States for the fee, mileage, or expenses of any witness, juror, deputy marshal, or any other officer of such court, shall 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., §193 (Mar. 4, 1909, ch. 321, §104, 35 Stat. 1107).
Word “Possession” was inserted to clarify scope of section.
Minor changes were made in phraseology.
Amendments
1994—Pub. L. 103–322 substituted “fined under this title” for “fined not more than $1,000”.
Change of Name
United States commissioners, referred to in text, were replaced by United States magistrates pursuant to Pub. L. 90–578, title IV, §402(b)(2), Oct. 17, 1968, 82 Stat. 1118. See chapter 43 (§631 et seq.) of Title 28, Judiciary and Judicial Procedure.
Reference to United States magistrate or to magistrate deemed to refer to United States magistrate judge pursuant to section 321 of Pub. L. 101–650, set out as a note under section 631 of Title 28.
Cross References
Assignment of claims, see section 3727 of Title 31, Money and Finance.
Fees, mileage, or expenses of—
Jurors, see sections 1824, 1871 of Title 28, Judiciary and Judicial Procedure.
Marshal's accounts, see section 567 of Title 28.
Witnesses, see sections 1821, 1824, 1825, 1920, 1922 of Title 28.