The first American coinage law was the Coinage act of 1792. It requires a depiction of an eagle on the back of every silver coin
So far as I can tell, after reading about all the later U.S. coin acts, the eagle requirement was never eliminated.
Enter a creativei
Christian Gobrecht in 1835. He went to work immediately, designing his famous eponymous dollar, revising Liberty Cap coins, half and cent designs.
In 1837 he began producing his entirely new Liberty Seated silver Coinage which dominated the rest of the Nineteenth Century. He also revised all gold and copper coinage. For a while every single coin minted in the U.S. was Gobrecht's design.
The requisite eagle led to a cramped eagle on the dime and a half-squashed
Half Dime eagle. Squeezed under a large scrolled E Pluribus Unum it made the reverse too crowded for Gobrecht's aesthetic vision. Gobrecht simply replaced the eagle on the dime and
Half Dime with a tasteful wreath. So far as I can tell he did this unilaterally, without any legal authority.
All later dime designers eliminated the eagle as well, but it has persisted on coins above the dime, including a teeny weenie little eagle on the
Franklin half.
Imagine that: Gobrecht the Renegade.
The Revolutionary Longacre took the coinage anarchy a step farther by eliminating both the eagle and the 1792 act-required Liberty inscription on the silver
Three Cent.
None of this matters much, but I wondered about the Gobrecht wreath being authorized and did a little research.