18 U.S.C. § 1991
Section 1991 · Entering train to commit crime
Amended 3 times on record
Applied in 4 court decisions — leading case State v. Young (1970)
Most recently applied in United States v. Altise Bridges (March 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.
Whoever, in any Territory or District, or within or upon any place within the exclusive jurisdiction of the United States, willfully and maliciously trespasses upon or enters upon any railroad train, railroad car, or railroad locomotive, with the intent to commit murder or robbery, shall be fined under this title or imprisoned not more than twenty years, or both.
Whoever, within such jurisdiction, willfully and maliciously trespasses upon or enters upon any railroad train, railroad car, or railroad locomotive, with intent to commit any unlawful violence upon or against any passenger on said train, or car, or upon or against any engineer, conductor, fireman, brakeman, or any officer or employee connected with said locomotive, train, or car, or upon or against any express messenger or mail agent on said train or in any car thereof, or to commit any crime or offense against any person or property thereon, shall be fined under this title or imprisoned not more than one year, or both.
Upon the trial of any person charged with any offense set forth in this section, it shall not be necessary to set forth or prove the particular person against whom it was intended to commit the offense, or that it was intended to commit such offense against any particular person.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
Based on title 18, U.S.C., 1940 ed., §522 (Mar. 4, 1909, ch. 321, §322, 35 Stat. 1150).
After the word “Whoever” the following was inserted: “in any Territory or District, or within or upon any place within the exclusive jurisdiction of the United States” as based upon the express provisions of title 18, U.S.C., 1940 ed., §511, wherein this section is made applicable only “in any Territory or District, or within or upon any place within the exclusive jurisdiction of the United States.”
Words “whoever shall counsel, aid, abet, or assist in the perpetration of any of the offenses set forth in this section shall be deemed to be a principal therein” were omitted as unnecessary. Such persons are made principals by section 2 of this title.
Minor changes also were made in phraseology.
Amendments
1996—Pub. L. 104–294 substituted “fined under this title” for “fined not more than $1,000” in second par.
1994—Pub. L. 103–322 substituted “fined under this title” for “fined not more than $5,000” in first par.
Canal Zone
Applicability of section to Canal Zone, see section 14 of this title.
Cross References
Destruction of property moving in commerce, see section 80501 of Title 49, Transportation.
Larceny, etc., of goods from railroad car or station, see section 659 of this title.
Railroad car entered or seal broken, see section 2117 of this title.
Wire or oral communications, authorization for interception, to provide evidence of murder or robbery, see section 2516 of this title.