In Rodgers v. United States, the Supreme Court was asked to determine whether a federal law that made it illegal for anyone to falsely represent themselves as an officer or employee of the U.S. government applied when someone impersonated a private individual who happened to be employed by the government. The case involved William P. Rodgers, who had been convicted of pretending to be another person in order to defraud people out of money and property; this other person was a postmaster, which is considered an officer of the U.S., but Rodgers argued that he should not have been charged under this specific statute because he did not pretend to hold any official position within the government himself. The court ruled against him, stating that his interpretation would defeat one purpose of such laws: protecting citizens from being deceived into parting with their property through false claims about governmental authority or influence. It held that even if someone only pretends to be an ordinary citizen who happens also work for the government (as opposed merely claiming directly hold some public office), they can still fall afoul these provisions if they use this deception in furtherance fraudulent schemes.

In the dissenting opinion for Rodgers v. United States, it was argued that the majority's decision to uphold a conviction based on an indictment which did not specifically state all elements of the crime was incorrect. The dissenting justices believed that this violated fundamental principles of criminal law and procedure, as well as constitutional guarantees of due process. They contended that every element necessary to constitute a crime must be clearly stated in an indictment so as to provide adequate notice to defendants about what they are charged with and why they are being prosecuted. In their view, failing to include such crucial information in an indictment renders it defective and invalidates any subsequent conviction based on it.