In the case of Culver v. United States, 1925, the U.S Supreme Court upheld a lower court's decision to convict Mr. Culver on charges of conspiracy to defraud the government by making false claims for compensation under federal workers' compensation laws. The defendant argued that his conviction was invalid because it was based on an indictment that did not specify which particular law he had conspired to violate and because some evidence used against him at trial should have been excluded as hearsay. However, the Supreme Court ruled against these arguments stating that an indictment does not need to specify which statute is involved in a conspiracy charge if it sufficiently describes the nature of the offense; and also held that while some statements admitted into evidence may have constituted hearsay, they were admissible under exceptions allowing such testimony when it goes towards proving intent or motive.

In the dissenting opinion for Culver v. United States, Justice Holmes argued that the defendant's conviction should be overturned due to a lack of evidence proving his intent to defraud. He believed that while Culver may have been guilty of making false statements, there was insufficient proof demonstrating he intended these falsehoods to deceive or cheat anyone out of their money or property. The majority had interpreted "intent" too broadly in this case and failed to consider whether Culver genuinely sought financial gain through deception. For Holmes, it was not enough for someone merely to lie; they must also intend harm by doing so - an element he found lacking in this case.