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Presidential or Legislative Pardon of the President
Under the fundamental rule that no one may be a judge in his own case, the President cannot pardon
himself.
If under the Twenty-Fifth Amendment the President declared that he was temporarily unable to perform
the duties of the office, the Vice President would become Acting President and as such could pardon
the President. Thereafter the President could either resign or resume the duties of his office.
Although as a general matter Congress cannot enact amnesty or pardoning legislation, because to do so
would interfere with the pardoning power vested expressly in the President by the Constitution, it
could be argued that a congressional pardon granted to the President would not interfere with the
President’s pardoning power because that power does not extend to the President himself.
August 5, 1974

https://www.justice.gov/file/20856/download