In United States v. Johnson , the United States Supreme Court ruled that the misbranding provisions of the 1906 Pure Food and Drugs Act did not pertain to false curative or therapeutic statements; rather, it only prohibited false statements as to the identity of the drug. In 1912, Congress responded with the Sherley Amendments, which addressed the perceived lack of enforcement of fraud related to therapeutic claims;: The Act was amended to prohibit false and fraudulent claims of health benefits, but enforcement under the amendment required proof of fraudulent intent, a difficult standard.