In the United States v. Noveck case in 1925, the Supreme Court ruled on a matter concerning false claims against the government. The defendant, Noveck, was charged with knowingly making and presenting to an officer of the United States a false claim against the government. He appealed his conviction arguing that he had not been properly indicted because his indictment did not charge him with intent to defraud or deceive any person or officer in particular. However, this argument was rejected by both lower courts and eventually by the Supreme Court as well. The court held that it is sufficient for an indictment under section 5438 (which makes it illegal to present fraudulent claims) to allege that defendant presented a claim knowing it to be false, fictitious or fraudulent without alleging intent specifically aimed at defrauding any individual person or officer within U.S Government service. It clarified that "intent" does not necessarily mean specific intention towards certain individuals but rather general knowledge of falsity when submitting such claims.

In the dissenting opinion for United States v. Noveck, Justice Oliver Wendell Holmes Jr. argued that a person cannot be convicted of perjury based on their belief about what is legally required in their testimony. He contended that if a witness believes they are not bound to answer truthfully because the question asked is not pertinent to the case, then they have not committed perjury even if it turns out later that they were mistaken in this belief. According to Holmes, such an individual has simply made an error of law and should not be held criminally liable for it as long as there was no intent to deceive or mislead the court.