United States v. Foster

Background

Harold A. Foster was the postmaster at the second-class North Brookfield, Massachusetts post office. Frank E. Winchell led a local corporation and bought large quantities of postage stamps from Foster to be sent to a New York company run by William S. Edwards and Harry H. Platt. The indictment charged the four with conspiring to buy and forward stamps so that the North Brookfield office’s reported gross receipts would appear larger, thereby increasing Foster’s salary for the next fiscal year. The indictment included an alleged false quarterly return and an overt act of purchasing stamps.

Reasoning

The Court addressed whether the Postmaster General could by regulation exclude large or unusual stamp sales intended for use at other offices from the “gross receipts” that determine a postmaster’s salary, and whether the facts charged amounted to crimes. Citing statutes that make it an offense to dispose of stamps improperly and to make false returns, the Court held that the regulation was a valid administrative rule under the Department’s authority. It concluded the indictment alleged unlawful sales and a conspiracy to increase salary by fraud, so dismissal was improper and the judgment was reversed.

Real world impact

The ruling lets criminal cases like this go forward and confirms that Post Office rules can treat out-of-office bulk stamp sales as excluded from salary calculations. Postmasters, businesses that buy stamps in bulk, and prosecutors will be affected because similar conduct can now be investigated and charged under the statutes and regulations.