The History of the Pardon Power
Article II, Section 2 of the United States Constitution states that the President has the authority to “grant Reprieves and Pardons for Offenses against the United States, except in Cases of Impeachment.” The United States Supreme Court has interpreted this power as “plenary,” meaning that is considerably broad and not generally subject to congressional modification.1 In both Ex parte Garland (1866) and United S