United States v. Sacks

Background

A man named Sacks was indicted in three counts after tearing stamps from a World War I–era war-savings certificate and keeping a portion of a certificate with stamps attached. The certificates and stamps were issued under a 1917 law that let the Treasury sell small-denomination savings certificates and to issue stamps as proof of payment. The certificates included conditions: a stamp must be affixed, certificates were not transferable, and holding limits applied. A lower court quashed the indictment, ruling the charges were not authorized under the statute.

Reasoning

The Court addressed whether the certificates and their stamps are United States obligations and whether removing stamps counts as altering those obligations. The Court said the Treasury had authority to create the certificates and to set conditions that make stamps essential to the certificate’s validity. Tearing off stamps defeated those conditions and thus altered the obligation. That alteration, when done with intent to defraud, falls within the federal criminal provisions making it illegal to alter, pass, or possess altered obligations of the United States.

Real world impact

The ruling lets the government proceed with criminal charges when people remove or tamper with war-savings stamps or certificates to evade the law’s limits or requirements. It protects the Treasury program’s rules on who may hold and transfer these certificates. The Court reversed the quashing of the indictment and sent the case back for further proceedings, so this decision allows prosecution but is not a final ruling on guilt.