In 1820, slave-trading became a capital offense with an amendment to the 1819 Act to Protect the Commerce of the United States and Punish the Crime of Piracy. A total of 74 cases of slaving were brought in the United States between 1837 and 1860, "but few captains had been convicted, and those had received trifling sentences, which they had usually been able to avoid". Nathaniel Gordon, who was hanged in 1862, was the only person to be executed for illegal slave-trading in the United States.