United States v. Speed 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 found until after the statute of limitations had expired. The defendant, Speed, was indicted for a crime that had occurred more than three years prior to the indictment. The Supreme Court held that the indictment was valid and that the defendant could be convicted of the crime. The Court reasoned that the statute of limitations was not a bar to prosecution, but rather a defense that the defendant could raise at trial. The Court noted that the statute of limitations was intended to protect defendants from having to defend themselves against stale charges, but that it did not prevent the government from bringing a valid indictment. The Court also noted that the statute of limitations was not a jurisdictional bar, and that the government could bring a valid indictment even if the statute of limitations had expired. In conclusion, the Supreme Court held that the indictment was valid and that the defendant could be convicted of the crime. The Court reasoned that the statute of limitations was not a bar to prosecution, but rather a defense that the defendant could raise at trial. The Court also noted that the statute of limitations was not a jurisdictional bar, and that the government could bring a valid indictment even if the statute of limitations had expired.

In United States v. Speed, the Supreme Court was tasked with determining whether a defendant could be convicted of an offense even if the indictment did not specify which particular statute he had violated. The majority opinion held that such convictions were valid as long as it was clear from the evidence presented at trial that the defendant had committed some criminal act and there was no prejudice to him in failing to identify precisely which law he had broken. In his dissent, Justice Field argued that this decision undermined fundamental principles of justice by allowing defendants to be convicted without knowing what they were being charged with or having any opportunity to defend themselves against those charges. He further contended that Congress should have been given more time before this ruling took effect so they could pass legislation addressing these issues if necessary.