Stuart v. United States was a United States Supreme Court case that addressed the issue of whether a defendant could be convicted of a crime if the indictment was not found until after the statute of limitations had expired. The case involved a man named William Stuart, who was indicted for a crime that had occurred more than three years prior. The indictment was found after the statute of limitations had expired, and Stuart argued that he could not be convicted of the crime because the indictment was found too late. The Supreme Court ultimately ruled in favor of the United States, finding that the statute of limitations did not apply in this case. The Court reasoned that the statute of limitations was intended to protect defendants from being prosecuted for crimes that had occurred too long ago, and that the statute of limitations did not apply in this case because the indictment was found before the statute of limitations had expired. The Court also noted that the statute of limitations was not intended to protect defendants from being prosecuted for crimes that had occurred too long ago, but rather to protect them from being prosecuted for crimes that had occurred too recently. In conclusion, the Supreme Court ruled that the statute of limitations did not apply in this case, and that William Stuart could be convicted of the crime even though the indictment was found after the statute of limitations had expired.

Justice Field delivered the dissenting opinion in Stuart v. United States, arguing that the majority's decision was a misinterpretation of the law and an infringement on personal liberty. He argued that Congress had no authority to pass laws criminalizing acts which were not considered crimes at common law, such as those committed by Stuart in this case. Furthermore, he asserted that even if Congress did have such authority it should be used sparingly and only when necessary for public safety or welfare; however, he believed there was no evidence to suggest either of these conditions applied here. Justice Field also noted that while some may argue against allowing individuals like Stuart to go unpunished for their actions due to technicalities of the law, it is more important for courts to uphold principles of justice than simply punish wrongdoers regardless of legal technicalities. In conclusion, Justice Field argued strongly against punishing individuals who commit acts which are not recognized as crimes under existing laws and urged his colleagues on the Court to reconsider their ruling in this case accordingly.