This section contains the nature of the case and procedural background.

McGovern (D1) owed Scull (D2) $1,800. D1 purchased $2,400 worth of travelers checks in New York and gave them to D2, authorizing D2 to sign D1's name as endorser. The purchaser's agreement signed by D1 specified that the purchaser was to sign each check at the time of purchase and to countersign each check in the presence of the person cashing them. D1 and D2 went to Pennsylvania, and D2 (after some practice) signed D1's name to the checks and cashed them. D1 then reported that the checks were missing and obtained replacements. D1 was convicted of transporting forged travelers checks across state lines. D appealed: he had authorized D2 to sign his name to the checks.

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