18 U.S.C. § 597
Section 597 · Expenditures to influence voting
Amended 3 times on record
Applied in 10 court decisions — leading case United States v. Adams (2013)
Most recently applied in Pennsylvania State Conference of NAACP Branches v. Northampton County Board of Elections (March 2024)
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 makes or offers to make an expenditure to any person, either to vote or withhold his vote, or to vote for or against any candidate; and
Whoever solicits, accepts, or receives any such expenditure in consideration of his vote or the withholding of his vote—
Shall be fined under this title or imprisoned not more than one year, or both; and if the violation was willful, shall be fined under this title or imprisoned not more than two years, or both.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Historical and Revision Notes
Based on sections 250, 252, of title 2, U.S.C., 1940 ed., The Congress (Feb. 28, 1925, ch. 368, title III, §§311, 314, 43 Stat. 1073, 1074).
This section consolidates the provisions of sections 250 and 252 of title 2, U.S.C., 1940 ed., The Congress.
Reference to persons causing or procuring was omitted as unnecessary in view of definition of “principal” in section 2 of this title.
The punishment provisions of section 252 of title 2, U.S.C., 1940 ed., The Congress, were incorporated at end of section upon authority of reference in such section making them applicable to this section.
Words “or both” were added to conform to the almost universal formula of the punishment provisions of this title.
Changes were made in phraseology.
Amendments
1996—Pub. L. 104–294 substituted “shall be fined under this title” for “shall be fined not more than $10,000” in last par.
1994—Pub. L. 103–322 substituted “shall be fined under this title” for “shall be fined not more than $1,000” in last par.
Cross References
Minor offenses tried by United States magistrate judges as excluding offenses punishable under this section, see section 3401 of this title.