Prussian v. United States

Background

A man named Prussian was convicted in federal court for forging an endorsement on a government draft issued by the Treasury. The indictment charged him under two different federal forgery laws: one that forbids forging an "obligation of the United States" and a broader one that forbids forging "other writings" to get money from the Government. The case reached the Supreme Court after lower courts disagreed on whether an endorsement counted as a United States obligation.

Reasoning

The Court looked at the text and history of the statutes. It explained that the law defining "obligations of the United States" refers to checks and drafts themselves, not the added signature or endorsement on the back. Criminal laws must be read narrowly, and the older obligation-forgery law was aimed at protecting government notes and bonds, not endorsements. At the same time, the Court found the endorsement fits the broader statute’s phrase "other writing" when forged for the purpose of getting money from a government officer. Because the indictment plainly alleged forgery of the endorsement to obtain money, the Court sustained the conviction under that broader provision.

Real world impact

People who forge endorsements on government checks can be prosecuted under the broad federal law that covers forged writings used to obtain money from the Government, even if endorsements are not treated as U.S. "obligations" under the narrower statute. The decision affirms the conviction and clarifies that separate statutes, including later laws specifically addressing pension checks and money orders, handle endorsements.