Cooper v. United States
Court of Appeals for the Fourth Circuit · 1926-04-13 · cited 11×
Cooper v. United States involved the conviction of William B. Cooper, a former bank president, on charges of misapplying bank funds and making false entries in violation of federal banking statutes, stemming from the discounting of accommodation notes for his brother that were known to be backed only by an insolvent maker. The trial court instructed the jury that authorizing the discounts with knowledge of their nature would support guilty verdicts on the relevant counts, and that accurate book entries of the transactions could still qualify as false entries if intended to deceive examiners. On appeal, the court reversed the convictions and remanded for a new trial, holding that the jury instructions misstated the law because an entry that truthfully records an actual transaction cannot constitute a false entry under the statute, even if the underlying transaction was improper. The decision relied on Supreme Court precedent emphasizing that the false-entry offense requires the entry itself to misrepresent the facts as they occurred.