United States v. McGovern

To repay a $1,800 debt to Scull, McGovern (defendants, together with Scull) bought $2,400 in Citibank traveler's checks whose purchase agreement required McGovern personally to sign each check at purchase and countersign it in the presence of the person cashing it. Scull instead signed McGovern's name and cashed the checks at banks and a store in Pennsylvania (crossing state lines to create federal jurisdiction), using McGovern's driver's license as fake identification. McGovern then falsely reported the checks stolen and collected $2,400 in replacement checks from Citibank. Both were charged with violating 18 U.S.C. Section 2314, which criminalizes transporting traveler's checks bearing a forged countersignature with fraudulent intent, and were convicted in a bench trial. They appealed, arguing the government failed to prove common-law forgery because McGovern had authorized Scull to sign his name.