 When it created the First Bank of the United States , Congress criminalized counterfeiting the bills of the bank . " Read literally , " the statute required both that the bill be counterfeit and that the bill be signed by the President of the Bank of the United States . In United States v. Cantril ( 1807 ) , without oral argument , the Court arrested a judgment of conviction under the counterfeiting statute , finding the statute invalid " for the reasons assigned in the record " ( without further elaboration ) . By the time Cantril was decided , Congress had already passed a new statute to correct the apparent drafting error . 
