In the 1909 case of Holmgren v. United States, the Supreme Court ruled on a matter involving counterfeit currency. The defendant, Mr. Holmgren, was convicted for having in his possession and attempting to sell counterfeit money. On appeal, he argued that there wasn't sufficient evidence to prove intent or knowledge that the bills were fake at the time of their sale; thus claiming innocence under federal law which required proof of such awareness for conviction. The Supreme Court disagreed with Holmgren's argument and upheld his conviction by stating that possession of a large amount of counterfeit money itself could be considered as evidence enough to infer knowledge and intent unless satisfactorily explained otherwise by the accused party. Furthermore, it was noted during trial proceedings that when arrested, Mr.Holmgren had attempted to throw away some counterfeit notes thereby indicating consciousness about their illegality. This act further substantiated prosecution’s claim regarding his guilty knowledge making it difficult for him to successfully argue against charges leveled upon him based on lack thereof.

In the dissenting opinion for Holmgren v. United States, Justice Harlan disagreed with the majority's interpretation of a statute that made it illegal to falsely make or forge any order in writing for money or other property from any person. The case involved a defendant who had forged an endorsement on a check drawn by another party. While the majority held that this constituted forging an "order" under the statute, Justice Harlan argued that such an interpretation was too broad and not consistent with Congress' intent when passing the law. He believed that Congress intended only to criminalize forgery of orders issued by one person directing another to pay money or deliver property, not endorsements on checks already issued by others.