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United States v. Rindskopf

• 1881 • 105 U.S. 418 • Waite Court
United States v. Rindskopf 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, Rindskopf, 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. Rindskopf argued that the indictment was invalid because...Open Case
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Chief Waite Court
Term: 1881
Docket: 881
105 U.S. 418
26 L. Ed. 1131
1881 U.S. LEXIS 2142
Argued: Mar 16, 1882

United States v. Rindskopf

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Opinion Summary
AI Abstract

United States v. Rindskopf 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, Rindskopf, 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. Rindskopf 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 Rindskopf could be convicted of the crime. The Court reasoned that the statute of limitations was not a bar to prosecution, but rather a limitation on the time within which the government must bring an indictment. The Court noted that the statute of limitations was intended to protect defendants from stale prosecutions, but that the defendant had not been prejudiced by the delay in this case. The Court also noted that the defendant had not taken any action to assert his rights under the statute of limitations. The Court concluded that the indictment was valid and that Rindskopf could be convicted of the crime. The Court's decision established that a defendant can be convicted of a crime even if the indictment is returned after the applicable statute of limitations has expired, as long as the defendant has not been prejudiced by the delay.

Dissent Summary
AI Abstract

In United States v. Rindskopf, the Supreme Court was tasked with determining whether a defendant who had been convicted of violating an act of Congress could be pardoned by the President and thereby have their conviction overturned. The majority opinion held that such a pardon would indeed overturn the conviction, but Justice Field dissented from this decision. He argued that while it is true that pardons are generally accepted as having power to absolve individuals from criminal liability for past offenses, they do not necessarily extend to civil cases where money damages were awarded against them in court proceedings prior to being granted a pardon. In his view, since no express language in either the Constitution or any federal statute indicated otherwise, he concluded that when someone has already been found guilty and ordered to pay damages due to their violation of an act of Congress then those damages should still stand even if they later receive a presidential pardon for said offense.

Opinion written by Justice SJField
Decided: Apr 24, 1882
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