 In June 1812 , during the War of 1812 , Congress passed a statute prohibiting the transportation " over land or otherwise , in any wagon , cart , sleigh , boat , or otherwise , naval or military stores , arms or the munitions of war , or any article of provision , from any place of the Uniteded States , to " Canada . In United States v. Barber ( 1815 ) , the Court held " fat cattle " to be " provisions , or munitions of war , within the true intent and meaning of the act . " In United States v. Sheldon ( 1817 ) , decided after the war had ended , Barber was distinguished on the grounds that driving cattle on foot was not " transportation " within the meaning of the act . 
