Section 641 of Title 18 of the U.S. Criminal Code is enacted. This section made it possible to hold anyone who “embezzles, steals, purloins, or knowingly converts to his use or the use of another, or without authority, sells, conveys or disposes of any record, voucher, money, or thing of value of the United States or of any department or agency” criminally liable for their actions.
Additionally, the statute holds anyone who “receives, conceals, or retains the same with intent to convert it to his use or gain, knowing it to have been embezzled, stolen, purloined or converted” criminally liable.
In the 1952 decision Morissette v. United States, the Supreme Court rules that criminal intent is necessary for convictions under this statute.
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