2 U.S.C. § 192
Section 192 · Refusal of witness to testify or produce papers
Amended 1 time on record
Applied in 221 court decisions — leading case United States v. Gaudin (1995)
Most recently applied in United States v. Stephen Bannon (May 2024)
Applied most in the District Circuit Circuit (80 decisions)
Cases citing this section usually also cite 18 U.S.C. § 371 · 2 U.S.C. § 194 · 21 U.S.C. § 841
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.
Every person who having been summoned as a witness by the authority of either House of Congress to give testimony or to produce papers upon any matter under inquiry before either House, or any joint committee established by a joint or concurrent resolution of the two Houses of Congress, or any committee of either House of Congress, willfully makes default, or who, having appeared, refuses to answer any question pertinent to the question under inquiry, shall be deemed guilty of a misdemeanor, punishable by a fine of not more than $1,000 nor less than $100 and imprisonment in a common jail for not less than one month nor more than twelve months.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Codification
R.S. §102 derived from act Jan. 24, 1857, ch. 19, §1, 11 Stat. 155.
Amendments
1938—Act June 22, 1938, reenacted section without change.
Cross References
Minor offenses tried by United States magistrate judges as excluding offenses punishable under this section, see section 3401 of Title 18, Crimes and Criminal Procedure.