 Congress passed a new counterfeiting statute in 1816 when it created the Second Bank of the United States. In United States v. Turner (1833), interpreting the new act, the Court held that the offense of counterfeiting was committed even if the signatures forged were those of the wrong bank officers. But, in United States v. Brewster (1833), the Court held that the crime applied only to counterfeit bills, not counterfeit notes.
