ral court was considered in determining the punishment for a
subsequent State offense. This conviction and sentence were upheld by
the Supreme Court. While this case involved offenses against different
sovereignties, the Court declared by way of dictum that its decision
"must not be understood as in the slightest degree intimating that a
pardon would operate to limit the power of the United States in
punishing crimes against its authority to provide for taking into
consideration past offenses committed by the accused as a circumstance
of aggravation even although for such past offenses there had been a
pardon granted."[137]

LIMITS TO THE EFFICACY OF A PARDON

But Justice Field's latitudinarian view of the effect of a pardon
undoubtedly still applies ordinarily where the pardon is issued _before
conviction_. He is also correct in saying that a full pardon restores a
_convict_ to his "civil rights," and this is so even though simple
completion of the convict's sentence would not have had that effect. One
such right is the right to testify in court, and in Boyd _v._ United
States the Court held that the disability to testify being a
consequence, according to principles of the common law, of the judgment
of conviction, the pardon obliterated that effect.[138] But a pardon
cannot "make amends for the past. It affords no relief for what has
been suffered by the offender in his person by imprisonment, forced
labor, or otherwise; it does not give compensation for what has been
done or suffered, nor does it impose upon the government any obligation
to give it. The offence being established by judicial proceedings, that
which has been done or suffered while they were in force is presumed to
have been rightfully done and justly suffered, and no satisfaction for
it can be required. Neither does the pardon affect any rights which have
vested in others directly by the execution of the judgment for the
offence, or which have been acquired by others whilst that judgment was
in force. If, for example, by the judgment a sale of the offender's
property has been had, the purchaser will hold the property
notwithstanding the subsequent pardon. And if the proceeds of the sale
have been paid to a party to whom the law has assigned them, they cannot
be subsequently reached and recovered by the offender. The rights of the
parties have become vested, and are as complete as if they were acquired
in any other legal way. So, also, if the proceed