In People v. Bel Air Equipment Corp. (39 N.Y.2d 48 [1976]), the Court of Appeals held that State vouchers used to make claims against the State are instruments within the meaning of Penal Law 175.35. The court held that the term "instrument" meant different things in different contexts, depending on the scope and purpose of a particular statute (id. at 54). The court held that in determining whether a document is an instrument within the meaning of a statute, it must construe whether (1) the document falls within the particular statutory prohibition, and (2) whether the document was of the type intended to be covered by the legislature in enacting the statute (id. at 55).