18 U.S.C. § 872
Section 872 · Extortion by officers or employees of the United States
Amended 4 times on record
Applied in 42 court decisions — leading case United States v. Little (1984)
Most recently applied in United States v. Michael Kimbrew (December 2019)
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 an officer, or employee of the United States or any department or agency thereof, or representing himself to be or assuming to act as such, under color or pretense of office or employment commits or attempts an act of extortion, shall be fined under this title or imprisoned not more than three years, or both; but if the amount so extorted or demanded does not exceed $1,000, he 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., §171 (Mar. 4, 1909, ch. 321, §85, 35 Stat. 1104).
Words “or any department or agency” were inserted to eliminate any possible ambiguity as to scope of section. (See definitive section 6 of this title.)
The punishment provided by section 171 of title 18, U.S.C., 1940 ed., of fine of not more than $500 or imprisonment of not more than 1 year, or both, was increased for offenses involving more than $100 to conform to Congressional policy reflected in later Acts. See section 4047(e)(1) of title 26, U.S.C., 1940 ed., Internal Revenue Code, and the punishment provision following paragraph (10) of said subsection.
Amendments
1996—Pub. L. 104–294 substituted “$1,000” for “$100”.
1994—Pub. L. 103–322 substituted “fined under this title” for “fined not more than $5,000” after “extortion, shall be” and for “fined not more than $500” after “he shall be”.
1951—Act Oct. 31, 1951, changed punctuation to make section applicable not only to persons falsely representing themselves as Federal officers or employees at the time of extortion or the attempt thereof, but also to Federal officers and employees who attempt or commit extortion under color of office or employment.
Cross References
Extortion by revenue officer or agent, see section 7214 of Title 26, Internal Revenue Code.