United States v. Irwin 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 returned within the time period prescribed by the applicable statute of limitations. The defendant, Irwin, was charged with a crime that had a three-year statute of limitations. The indictment was returned more than three years after the alleged crime was committed. Irwin argued that the indictment was invalid because it was returned after the statute of limitations had expired. The Supreme Court held that the indictment was valid and that Irwin could be convicted of the crime. The Court reasoned that the statute of limitations was not a jurisdictional bar to prosecution, but rather a defense that could be waived by the defendant. The Court noted that Irwin had not raised the statute of limitations as a defense in the lower court, and thus had waived his right to do so. The Court also noted that the statute of limitations was intended to protect defendants from stale prosecutions, and that Irwin had not been prejudiced by the delay in the indictment. The Court concluded that Irwin could be convicted of the crime, and that the indictment was valid. The Court's decision established that a defendant can waive the statute of limitations defense and be convicted of a crime even if the indictment is returned after the statute of limitations has expired.

In United States v. Irwin, the Supreme Court was asked to decide whether a criminal defendant could be retried after an appeal of his conviction had been granted due to errors in the trial court's instructions. The majority opinion held that a retrial was permissible under these circumstances, but Justice Field dissented from this ruling. He argued that allowing for retrials would lead to double jeopardy and violate the Fifth Amendment's protection against being tried twice for the same offense. Furthermore, he noted that such retrials were not authorized by any statute or rule of law and thus should not be allowed as it would create "a new principle" which is contrary to established legal principles regarding double jeopardy protections. In conclusion, Justice Field argued that permitting retrials in this case would set a dangerous precedent and undermine fundamental constitutional rights guaranteed by the Fifth Amendment