36 U.S.C. § 114
Section 114 · Leif Erikson Day
Amended 1 time on record
Applied in 5 court decisions — leading case Crum v. Veterans of Foreign Wars (1980)
Most recently applied in Doe v. American National Red Cross (February 1994)
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.
The President may issue each year a proclamation designating October 9 as Leif Erikson Day.