United States v. Germaine was a United States Supreme Court case that dealt with 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 defendant, Germaine, was indicted for a crime that had occurred more than three years prior to the indictment. The Supreme Court held that the indictment was valid and that the defendant could be convicted of the crime. The Court reasoned that the statute of limitations was not a bar to prosecution, but rather a defense that the defendant could raise at trial. The Court noted that the statute of limitations was intended to protect defendants from having to defend themselves against stale charges, but that it did not prevent the government from bringing a valid indictment. The Court also noted that the defendant had not been prejudiced by the delay in the indictment, as he had not been arrested or otherwise hindered in his ability to defend himself. In conclusion, the Supreme Court held that the indictment was valid and that the defendant could be convicted of the crime. The Court noted that the statute of limitations was a defense that the defendant could raise at trial, but that it did not prevent the government from bringing a valid indictment.

In United States v. Germaine, the Supreme Court was asked to decide whether a defendant who had been convicted of an offense against the United States could be pardoned by the President and then have his conviction set aside. The majority opinion held that such a pardon would not be effective in setting aside a conviction because it did not amount to an acquittal or discharge from punishment for the crime committed. Justice Field dissented, arguing that since there is no express provision in either federal or state constitutions prohibiting presidential pardons from being used to set aside convictions, they should be allowed as long as they are within constitutional limits. He argued that if Congress has given power to grant pardons for offenses against the United States, then this power must include authority over convictions already rendered and sentences imposed upon them; otherwise it would render much of its purpose ineffective. Furthermore, he argued that allowing presidential pardons to set aside convictions does not interfere with judicial proceedings but rather serves as another means of providing relief when justice requires it.