18 U.S.C. § 2345
Section 2345 · Effect on State and local law
Amended 2 times on record
Applied in 4 court decisions — leading case Villarreal v. R.J. Reynolds Tobacco Co. (2016)
Most recently applied in Villarreal v. R.J. Reynolds Tobacco Co. (October 2016)
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) Nothing in this chapter shall be construed to affect the concurrent jurisdiction of a State or local government to enact and enforce its own cigarette tax laws, to provide for the confiscation of cigarettes or smokeless tobacco and other property seized for violation of such laws, and to provide for penalties for the violation of such laws.
(b) Nothing in this chapter shall be construed to inhibit or otherwise affect any coordinated law enforcement effort by a number of State or local governments, through interstate compact or otherwise, to provide for the administration of State or local cigarette tax laws, to provide for the confiscation of cigarettes or smokeless tobacco and other property seized in violation of such laws, and to establish cooperative programs for the administration of such laws.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Amendments
2006—Pub. L. 109–177, §121(g)(2), substituted “Effect on State and local law” for “Effect on State law” in section catchline.
Subsec. (a). Pub. L. 109–177, §121(b)(5), (e)(1), substituted “a State or local government to enact and enforce its own” for “a State to enact and enforce” and inserted “or smokeless tobacco” after “cigarettes”.
Subsec. (b). Pub. L. 109–177, §121(b)(5), (e)(2), substituted “of State or local governments, through interstate compact or otherwise, to provide for the administration of State or local” for “of States, through interstate compact or otherwise, to provide for the administration of State” and inserted “or smokeless tobacco” after “cigarettes”.