 In United States v. <unk> ( 1826 ) , the Court held that the federal criminal insurance fraud statute was no subjected to the same formalities as civil insurance fraud claims . First , the Court held that the state statute of incorporation of the insurance company required no more than the state 's seal to be authenticated . Second , there was no need to prove the existence of the insurance company ( i.e. , that its stock had actually been subscribed ) because it was not a party . Nor was it necessary to prove that the policy would have been binding against the insurance company . Nor did it matter whether the policy would have paid out under the circumstances of the fraud . Finally , it was held that an insurance corporation was a person within the meaning of the statute . 
