In the 1914 case Burdick v. United States, the U.S Supreme Court ruled that a pardon carries an imputation of guilt and acceptance of a pardon is an admission of guilt. This ruling came about when George Burdick, who was city editor for The New York Tribune newspaper, refused to testify regarding sources used in articles about custom frauds on grounds that his testimony could incriminate him. President Woodrow Wilson granted him full immunity but he still declined to testify arguing that he had not asked for any pardon or immunity and therefore did not have to accept it. He was then held in contempt by two lower courts before appealing at the Supreme Court level where they reversed these decisions stating that pardons must be accepted by individuals as they carry implications of confession which cannot be forced upon anyone.

The dissenting opinion in Burdick v. United States argued that the majority's interpretation of the pardon power was too narrow and inconsistent with historical practice. The dissenters believed that a pardon should be considered effective once it is issued, regardless of whether or not it is accepted by the individual to whom it is granted. They contended that this approach would better serve public policy objectives, as it would allow for more efficient administration of justice and prevent individuals from manipulating pardons to their advantage. Furthermore, they disagreed with the majority's view that acceptance implies admission of guilt; instead, they saw pardons as acts of grace which do not necessarily carry any implication about an individual's innocence or guilt.