28 U.S.C. § 2322
Section 2322 · United States as party
Amended 1 time on record
Applied in 52 court decisions — leading case United States v. ICC (1949)
Most recently applied in Mail Order Ass'n of America v. United States Postal Service (January 1993)
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.
All actions specified in section 2321 of this title shall be brought by or against the United States.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
Based on title 28, U.S.C., 1940 ed., §48 (Mar. 3, 1911, ch. 231, §211, 36 Stat. 1150; Oct. 22, 1913, ch. 32, 38 Stat. 219).
Word “actions” was substituted for “cases and proceedings”, in view of Rule 2 of the Federal Rules of Civil Procedure.
A provision authorizing intervention by the United States was omitted. The United States, under the provisions of this section, is a necessary and indispensable original party, and hence intervention is unnecessary. (See Lambert Run Coal Co. v. Baltimore & O. R. Co., 1922, 42 S.Ct. 349, 258 U.S. 377, 66 L.Ed. 671.)