Befitting its royal heritage, the presidential pardoning power is subject to few constitutional restraints, and only then in rare and unlikely circumstances. In theory, judicial review and impeachment are available to restrain the pardon power, but in practice they are not to be invoked unless the President abuses the power excessively or otherwise administers it in a grossly arbitrary manner. Contrary, therefore, to Supreme Court dictum and scholarly assertions of an illimitable power to pardon, there are boundaries that fence the exercise of executive clemency. Nevertheless, it is easier to speak of abuses, as opposed to illegal uses, of the pardon authority. The principal restriction on the power remains political, to be exercised by Americans on Election Day.