In the 1890 case of In re Wilson, petitioner James Wilson was sentenced to death for murder. However, President Benjamin Harrison granted him a respite until further action from the executive branch. The Supreme Court had to determine whether this constituted a reprieve or commutation of sentence and if it interfered with their jurisdiction over the case. The court ruled that only an unconditional pardon by the president could remove a federal criminal conviction and its associated penalties; anything less than that (like a respite) would not interfere with judicial proceedings or decisions. Therefore, they concluded that they still held jurisdiction over Wilson's case despite his temporary relief from execution granted by President Harrison.

The dissenting opinion in the case of In re Wilson, 1890, argued that the President's power to pardon should not be limited by judicial interpretation. The dissenting justices believed that this power was absolute and unrestricted as granted by the Constitution. They contended that once a presidential pardon is issued, it becomes effective immediately without requiring any further action or acceptance from the person being pardoned. This view contradicted with majority's ruling which held that a presidential pardon must be delivered and accepted to take effect. The dissenters also disagreed with majority’s reliance on English common law principles for their decision-making process because they felt these were irrelevant since U.S constitution had clearly defined Presidential powers including pardoning authority.