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United States v. Kimbal

• 1871 • 80 U.S. 636 • Chase Court
United States v. Kimbal 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 Court held that the defendant could not be convicted if the indictment was not returned within the time period prescribed by the applicable statute of limitations. The case arose when the defendant, William Kimbal, was indicted for a crime...Open Case
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Chief Chase Court
Term: 1871
80 U.S. 636
20 L. Ed. 503
1871 U.S. LEXIS 1378
Argued: Nov 14, 1871

United States v. Kimbal

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Opinion Summary
AI Abstract

United States v. Kimbal 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 Court held that the defendant could not be convicted if the indictment was not returned within the time period prescribed by the applicable statute of limitations. The case arose when the defendant, William Kimbal, was indicted for a crime that was alleged to have been committed more than three years prior to the indictment. The applicable statute of limitations provided that an indictment must be returned within three years of the commission of the crime. The defendant argued that the indictment was not returned within the time period prescribed by the applicable statute of limitations and, therefore, he could not be convicted. The Supreme Court agreed with the defendant and held that the indictment was not returned within the time period prescribed by the applicable statute of limitations and, therefore, the defendant could not be convicted. The Court reasoned that the statute of limitations was intended to protect defendants from being prosecuted for crimes that were committed long ago and that the defendant should not be punished for the government's failure to return the indictment within the time period prescribed by the statute of limitations. The Court's decision in United States v. Kimbal established that a defendant cannot be convicted of a crime if the indictment was not returned within the time period prescribed by the applicable statute of limitations. This decision has been cited in numerous subsequent cases and has become an important part of criminal law in the United States.

Dissent Summary
AI Abstract

In United States v. Kimbal, the Supreme Court was asked to decide whether a defendant could be convicted of aiding and abetting another person in committing an offense against the United States without being present at the time of commission. The majority opinion held that such conviction was permissible under existing law, but Justice Field dissented on this point. He argued that it would be unjust to convict someone who had not been present when the crime occurred because they were unable to defend themselves or provide any evidence as to their innocence. Furthermore, he noted that there is no precedent for such a conviction and thus it should not be allowed by courts unless Congress specifically authorizes it through legislation. In conclusion, Justice Field believed that allowing convictions based solely on circumstantial evidence without requiring physical presence at the scene of a crime would lead to injustice and should therefore not be permitted under current law.

Opinion written by Justice NHSwayne
Decided: Dec 11, 1871
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