18 U.S.C. § 548
Section 548 · Removing or repacking goods in warehouses
Amended 2 times on record
Applied in 22 court decisions — leading case Rice v. Olson (1945)
Most recently applied in Hatfield v. Sessions (April 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 fraudulently conceals, removes, or repacks merchandise in any bonded warehouse or fraudulently alters, defaces or obliterates any marks or numbers placed upon packages deposited in such warehouse, shall be fined under this title or imprisoned not more than two years, or both.
Merchandise so concealed, removed, or repacked, or packages upon which any marks or numbers have been so altered, defaced, or obliterated, shall be forfeited to the United States.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
Based on section 1597 of title 19, U.S.C., 1940 ed., Customs Duties (June 17, 1930, ch. 497, title IV, §597, 46 Stat. 752).
This section was rewritten to place the criminal provisions ahead of the forfeiture provisions. This did not require any substantive changes except omission of reference to persons aiding. Such persons are made principals by section 2 of this title.
The punishment prescribed by section 545 of this title was inserted to make this section complete without reference to another section. In doing so it was necessary to rephrase the punishment provision of section 545 of this title, as originally enacted, without change of substance.
Forfeiture provision was rephrased to make it clear that forfeiture was not dependent upon conviction.
Changes were made in phraseology.
Amendments
1994—Pub. L. 103–322 substituted “fined under this title” for “fined not more than $5,000”.