18 U.S.C. § 894
Section 894 · Collection of extensions of credit by extortionate means
Amended 2 times on record
Applied in 334 court decisions — leading case United States v. Angiulo (1990)
Most recently applied in United States v. Lavelle Hatley (March 2023)
Applied most in the Second Circuit Circuit (58 decisions)
Cases citing this section usually also cite 18 U.S.C. § 1962 · 18 U.S.C. § 891 · 18 U.S.C. § 892
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.
(a) Whoever knowingly participates in any way, or conspires to do so, in the use of any extortionate means
(1) to collect or attempt to collect any extension of credit, or
(2) to punish any person for the nonrepayment thereof,
shall be fined under this title or imprisoned not more than 20 years, or both.
(b) In any prosecution under this section, for the purpose of showing an implicit threat as a means of collection, evidence may be introduced tending to show that one or more extensions of credit by the creditor were, to the knowledge of the person against whom the implicit threat was alleged to have been made, collected or attempted to be collected by extortionate means or that the nonrepayment thereof was punished by extortionate means.
(c) In any prosecution under this section, if evidence has been introduced tending to show the existence, at the time the extension of credit in question was made, of the circumstances described in section 892(b)(1) or the circumstances described in section 892(b)(2), and direct evidence of the actual belief of the debtor as to the creditor's collection practices is not available, then for the purpose of showing that words or other means of communication, shown to have been employed as a means of collection, in fact carried an express or implicit threat, the court may in its discretion allow evidence to be introduced tending to show the reputation of the defendant in any community of which the person against whom the alleged threat was made was a member at the time of the collection or attempt at collection.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Amendments
1994—Subsec. (a). Pub. L. 103–322 substituted “fined under this title” for “fined not more than $10,000” in concluding provisions.
Cross References
Wire or oral communications, authorization for interception, to provide evidence of offenses under this section, see section 2516 of this title.