 The U.S. federal government had issued paper money known as United States Notes during the American Civil War, pursuant to the terms of the Legal Tender Act of 1861.In the 1869 case of "Hepburn v. Griswold", the Court had held that the Legal Tender Act violated the due process clause of the Fifth Amendment to the United States Constitution.In his majority opinion, Chief Justice Salmon P. Chase did not hold that Congress lacked the power to issue paper money, but rather ruled that the notes could not be used as legal tender for "pre-existing" debts.