United States v. Landram 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 failed to allege the essential elements of the offense. The defendant, Landram, was charged with the crime of counterfeiting coins. The indictment failed to allege that the coins were counterfeit, and the Supreme Court held that the indictment was insufficient to sustain a conviction. The Court reasoned that the indictment must allege all of the essential elements of the offense in order to be sufficient. The Court noted that the indictment must be specific enough to inform the defendant of the charges against him and to protect him from being tried twice for the same offense. The Court held that the indictment in this case was insufficient because it failed to allege that the coins were counterfeit. As a result, the Court reversed the conviction and remanded the case for further proceedings.

In United States v. Landram, the Supreme Court was tasked with deciding whether a defendant who had been convicted of violating an act of Congress could be sentenced to pay a fine and serve time in prison for their offense. The majority opinion held that such sentences were permissible under the law, but Justice Field dissented from this ruling. He argued that while it may have been within Congress' power to pass laws allowing for both fines and imprisonment as punishment for certain offenses, they did not do so in this case; instead, only one or the other penalty was authorized by statute. Furthermore, he noted that if courts are allowed to impose both penalties on defendants regardless of what is specified by law then there would be no limit on punishments imposed upon those found guilty of crimes - something which he believed should not be done without explicit authorization from Congress itself.