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Statutory Criminal Contempt: If Congress refers a contempt case to the Department of Justice (DOJ) for prosecution under 2 U.S.C. § 192, this is a federal crime that the President can pardon.
Inherent/Civil Contempt: If Congress uses its own power to detain someone until they comply, or seeks a court order to hold someone until they comply, a pardon cannot free them because the purpose is to compel action, not punish a past crime.
Limitations: The President cannot pardon contempt related to impeachment.
Precedent: While Ex parte Grossman (1925) established that the President can pardon criminal contempt of a federal court, the application to contempt of Congress, particularly the rarely used inherent contempt, remains a topic of legal debate