of not more than $500, or by imprisonment not more than one year, according to the aggravation of his offence. In United States v. Germaine (1878), the Court held that § 12 applied only to defendants who were officers within the meaning of the Appointments Clause of Article Two of the United States Constitution. Because Germaine (a surgeon appointed by the Commissioner of Pensions) was not appointed by the President, a court of law, or a head of a department, the Court held that he was not covered by the statute. The key dispute was whether the Commissioner of Pensions was a head of a department. Germaine held that the phrase "Heads of Departments" in the Appointments Clause had the same referent as the phrase "principal Officer" in the Opinions Clause of Article Two. Further, the Court held the definition of "inferior Officer[]" turned on "tenure, duration, emolument, and duties [that] were continuing and permanent, not occasional or temporary." Fraud on the United States An 1873 statute punished fraud in connection with claims against the United States. In United States v. Hall (1878), the Court upheld the conviction of a ward who had withheld from a guardian the proceeds of such a claim. In United States v. Benecke (1878), the Court held that the statute did not apply to money withheld before its passage. In United States v. Irvine (1878), a prosecution concerning a lawyer who withheld money from a client, the Court held that the crime was not a continuing offense was thus was susceptible to the statute of limitations. In United States v. Hirsch (1879), the Court held that the crime was subject to a 5-year statute of limitations, rather than the 3-year statute of limitations under the revenue laws. Mail fraud In Ex parte Henry (1887), the Court held that each mailing can form the basis for a separate count of mail fraud. Perjury In United States v. Curtis (1883), the Court held that a false oath taken before a notary public could not be the basis for a perjury conviction because a notary has no power to issue such an oath. But, in United States v. Ambrose (1883), the Court held that an accounting of services given to a clerk of court is a "certification" covered by the statute. Private money In United States v. Van Auken (1877), the Court held that the offense of circulating