private legal tender did not apply to the circulation of a bill which stated that it was payable in goods only. Revenue laws In United States v. Norton (1875), the Court held that the embezzlement of postal money orders was not an offense under the revenue laws. In United States v. Spiegel (1886), the Court held that possession of an uncancelled stamp for imported liquors was not a crime unless it had been intentionally removed. Trademark In the Trade-Mark Cases (1879), a criminal prosecution under the new trademark law, the Court found the act unconstitutional under the Copyright Clause. Federal jurisdiction Indian country In United States v. McBratney (1881), the Court held that the federal government had failed to reserve criminal jurisdiction over Indian country in Colorado upon its admission as a U.S. state. Thus, it had no jurisdiction to try the murder of a non-Indian by a non-Indian on the Ute reservation. In Ex parte Crow Dog (1883), the Court held that the Nonintercourse Act of 1834's exception for Indian-on-Indian crimes had not been repealed by the "bad men" clause of a treaty, and that therefore there was no federal jurisdiction to try such a crime. Congress responded by passing the Major Crimes Act. In United States v. Kagama (1886), the Court upheld the Major Crimes Act. Federal officer removal In Tennessee v. Davis (1879), the Court upheld the federal officer removal component of the Reconstruction-era removal statute (the civil rights removal component of which had come before the Chase Court). Davis v. South Carolina (1883) concerned an attempt by a state court to continue criminal proceedings in spite of an effected federal officer removal. On the merits, the Court held that an assistant U.S. Marshall was entitled to official immunity. Further, the Court held that bail could not be forfeited for failing to appear in state court after the removal. Courts-martial In Ex parte Reed (1879), the Court held that the clerk of the navy postmaster could permissible be tried by courts martial. In Ex parte Mason (1881), the Court held that courts martial jurisdiction extended to a military prison shooting and that the courts martial had the power to add a dishonorable discharge onto the maximum sentence authorized by Congress. Criminal procedure Constitutional issues Confrontation Clause Reynolds v. United States (1878) was the first Supreme Court case where the defendant raised a Confrontation Clause issue. The Court