In the United States v. Rogers et al., 1920, the Supreme Court dealt with a case involving fraudulent use of mails and conspiracy to defraud. The defendants were charged with using mail for fraudulent purposes, specifically sending letters containing false statements about oil leases they were selling in order to deceive potential buyers. They appealed their conviction on several grounds including that there was insufficient evidence to support it and that certain instructions given by the trial judge were erroneous. The Supreme Court upheld their convictions, ruling that there was ample evidence supporting them and rejecting all other arguments made by the defendants. It held that even if some parts of a letter are true but others are false or misleading, then it can still be considered as being sent for fraudulent purposes under law. Furthermore, it ruled against defendant's argument regarding instruction given by trial judge stating "intent" is not necessary element in proving fraud; rather only requirement is showing deception which leads recipient into error.

The dissenting opinion in the United States v. Rogers et al., 1920 case argued that the majority's decision to uphold a conviction for conspiracy to defraud the government was incorrect because it relied on an overly broad interpretation of "conspiracy." The dissenting justices believed that not every agreement or understanding between two parties should be considered a criminal conspiracy, especially if there is no clear intent to commit fraud. They also disagreed with the majority's view that any action taken by conspirators towards achieving their goal constitutes an overt act necessary for prosecution. Instead, they contended that only actions directly contributing to fraudulent activity should count as overt acts under law. Therefore, they would have reversed and remanded this case back down for further proceedings based on these principles.