"The US Constitution (Article II, Section 2, Clause 1) grants the President the exclusive power to issue pardons. This power is considered a core executive function requiring the President's personal judgment. While no specific law prohibits using an autopen, concerns arise because the act of pardoning necessitates presidential deliberation, which a mechanical device lacks. Legal principles emphasizing authentic records and the personal nature of executive powers support the argument that autopen-signed pardons could be deemed invalid due to a lack of the President's direct exercise of this constitutional authority."

- Errol Anthony Smythe