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Index/Topics/18 U.S.C. § 111 Circuit Split

18 U.S.C. § 111 Circuit Split

The circuit split regarding the interpretation of 18 U.S.C. § 111, specifically whether it requires proof of the common-law offense of simple assault as an element of at least some § 111 prosecutions.

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Jan 14, 2026

Which circuits have held that § 111 requires common-law simple assault and what are their leading opinions?

Three federal circuits have held that 18 U.S.C. § 111 requires proof of the common‑law offense of simple assault as an element of at least some § 111 prosecutions, while at least four other circuits h...