18 U.S.C. § 931
Section 931 · Prohibition on purchase, ownership, or possession of body armor by violent felons
Amended 1 time on record
Applied in 68 court decisions — leading case Byrd v. United States (2018)
Most recently applied in United States v. Howald (June 2024)
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) In General.—Except as provided in subsection (b), it shall be unlawful for a person to purchase, own, or possess body armor, if that person has been convicted of a felony that is—
(1) a crime of violence (as defined in section 16); or
(2) an offense under State law that would constitute a crime of violence under paragraph (1) if it occurred within the special maritime and territorial jurisdiction of the United States.
(b) Affirmative Defense.—
(1) In general.—It shall be an affirmative defense under this section that—
(A) the defendant obtained prior written certification from his or her employer that the defendant's purchase, use, or possession of body armor was necessary for the safe performance of lawful business activity; and
(B) the use and possession by the defendant were limited to the course of such performance.
(2) Employer.—In this subsection, the term “employer” means any other individual employed by the defendant's business that supervises defendant's activity. If that defendant has no supervisor, prior written certification is acceptable from any other employee of the business.