These examples undoubtedly were known to early American commentators and jurists, who often reiterated the importance of clarity in criminal statutes. James Madison in Federalist No. 62 warns of the “calamitous” results if laws are “so incoherent that they cannot be understood. . . .” In an early federal court case, United States v. Sharp (1815), the Court argued that laws that “create crimes, ought to be so explicit in themselves, or by reference to some other standard, that all men, subject to their penalties, may know what acts it is their duty to avoid.”