United States v. Howell 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 did not specify the exact date of the offense. The case involved a defendant, Howell, who was charged with the crime of embezzlement. The indictment against Howell did not specify the exact date of the offense, but instead stated that the offense occurred "on divers days between the first day of January, 1867, and the first day of January, 1868." The Supreme Court held that the indictment was sufficient to sustain a conviction. The Court reasoned that the indictment provided enough information to put Howell on notice of the charges against him and to allow him to prepare a defense. The Court also noted that the indictment provided a definite time frame for the offense, which was sufficient to protect Howell from being charged with an offense that occurred outside of the time frame specified in the indictment. In conclusion, the Supreme Court held that the indictment against Howell was sufficient to sustain a conviction, as it provided enough information to put Howell on notice of the charges against him and to allow him to prepare a defense. The Court also noted that the indictment provided a definite time frame for the offense, which was sufficient to protect Howell from being charged with an offense that occurred outside of the time frame specified in the indictment.

In United States v. Howell, the Supreme Court was tasked with determining whether a federal statute that allowed for the forfeiture of property used in violation of certain laws applied to an individual who had been convicted under state law. The majority opinion held that it did not, as Congress had only intended for this provision to apply when someone violated a federal law. In his dissenting opinion, Justice Field argued that Congress' intent should be interpreted broadly and thus could include violations of state laws as well. He reasoned that since the language in question was broad enough to encompass both types of offenses, it should be read accordingly and enforced against those found guilty by either type of court system. Furthermore, he noted how such an interpretation would help ensure uniformity across all states and territories governed by U.S. law while still allowing each jurisdiction some degree of autonomy over its own criminal justice system