22 U.S.C. § 1732
Section 1732 · Release of citizens imprisoned by foreign governments
Amended 1 time on record
Applied in 21 court decisions — leading case Dames & Moore v. Regan (1981)
Most recently applied in Center for Biological Diversity v. Hagel (February 2015)
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.
Whenever it is made known to the President that any citizen of the United States has been unjustly deprived of his liberty by or under the authority of any foreign government, it shall be the duty of the President forthwith to demand of that government the reasons of such imprisonment; and if it appears to be wrongful and in violation of the rights of American citizenship, the President shall forthwith demand the release of such citizen, and if the release so demanded is unreasonably delayed or refused, the President shall use such means, not amounting to acts of war and not otherwise prohibited by law, as he may think necessary and proper to obtain or effectuate the release; and all the facts and proceedings relative thereto shall as soon as practicable be communicated by the President to Congress.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Codification
R.S. §2001 derived from act July 27, 1868, ch. 249, §3, 15 Stat. 224.
Section was formerly classified to section 903b of Title 8, Aliens and Nationality.
Amendments
1989—Pub. L. 101–222 inserted “and not otherwise prohibited by law” after “acts of war”.
Release of American Hostages in Iran
For Executive Order provisions relating to the release of the American hostages in Iran, see Ex. Ord. Nos. 12276 to 12285, Jan. 19, 1981, 46 F.R. 7913 to 7932, set out as notes under section 1701 of Title 50, War and National Defense.