Court held that the jurisdiction strip at issue in McCardle did not revoke the Court's authority to hear original habeas petitions under § 14 of the Judiciary Act of 1789. Other than Yerger, the Court only had one additional opportunity to hear such an original habeas case. Certificates of division Despite intervening statutory developments that decreased the likelihood of division in the circuit courts, the Chase Court heard seventeen of its thirty-six criminal cases on certificates of division. In Ex parte Milligan (1866), the Court held that habeas petitions in the circuit courts could be a source of certified questions to the Supreme Court. But, in United States v. Rosenburgh (1868) and United States v. Avery (1871), the Court held that a motion to quash an indictment could not be so certified, even if the motion calls into question the jurisdiction of the circuit court. Prerogative writs In Ex parte Robinson (1873), on a petition for a writ of mandamus, the Court held that fines and imprisonment are the only punishments authorized by the Judiciary Act of 1789 for contempt of court. Thus, where attorney misconduct took place before a criminal grand jury, the Court held that the attorney could not be disbarred for contempt. Defining federal crimes Alien crew members In United States v. Tynen (1870), the Court overturned a conviction under a statute that required vessel owners to only employ U.S. citizen crew members. The Court held that a new statute which did no more than increase the punishment operated as an implied repeal of the first statute, and thus a conviction under the first statute was invalid. Counterfeiting In United States v. Howell (1870), the Court held that a counterfeiting statute was not void for repugnancy, distinguishing United States v. Cantril (1807), a decision of the Marshall Court interpreting a nearly identical statute. Draft obstruction A Civil War-era statute prohibited obstruction of the draft or the enrollment of members in the armed forces. The Court repeatedly upheld a strict division between the two prohibitions, holding that the draft obstruction provision did not apply to enrollment obstruction and vice versa. Embezzlement In United States v. Hartwell (1867), a prosecution for embezzlement of government funds under the Sub-Treasury Act, the Court held that the prohibition applied even to a relatively low level government official. Liquor In United States v. Holliday (1865), the Court upheld a criminal prohibition on selling