18 U.S.C. § 372
Section 372 · Conspiracy to impede or injure officer
Amended 2 times on record
Applied in 59 court decisions — leading case Windsor v. The Tennessean (1983)
Most recently applied in United States v. Duane Ehmer (December 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.
If two or more persons in any State, Territory, Possession, or District conspire to prevent, by force, intimidation, or threat, any person from accepting or holding any office, trust, or place of confidence under the United States, or from discharging any duties thereof, or to induce by like means any officer of the United States to leave the place, where his duties as an officer are required to be performed, or to injure him in his person or property on account of his lawful discharge of the duties of his office, or while engaged in the lawful discharge thereof, or to injure his property so as to molest, interrupt, hinder, or impede him in the discharge of his official duties, each of such persons shall be fined under this title or imprisoned not more than six years, 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., §54 (Mar. 4, 1909, ch. 321, §21, 35 Stat. 1092).
Scope of section was enlarged to cover all possessions of the United States. When the section was first enacted in 1861 there were no possessions, and hence the use of the words “State or Territory” was sufficient to describe the area then subject to the jurisdiction of the United States. The word “District” was inserted by the codifiers of the 1909 Criminal Code.
Amendments
2002—Pub. L. 107–273 substituted “under this title” for “not more than $5,000”.