Brown v. Ohio case brief

Brown v. Ohio case brief summary
432 U.S. 161 (1977)

CASE SYNOPSIS

Defendant sought review of the decision of the Court of Appeals of Ohio affirming the decision of the lower court that determined that the government's indictments for stealing an automobile and operating a vehicle without the owner's consent (joyriding) were not barred by the double jeopardy clause, U.S. Constitutional Amendment V, when defendant had already pleaded guilty in another county for joyriding and the two actions arose out of the same incident.

CASE FACTS

• Defendant stole a car from an East Cleveland, Ohio parking lot and was caught nine days later in Wickliffe, Ohio. 
• Defendant pleaded guilty to the crime of operating a vehicle without the owner's consent (joyriding) after the charges were brought by Wickliffe officials. 
• Defendant was then returned to East Cleveland where he was charged with stealing an automobile (auto theft) from the same incident. 
• The trial court overruled defendant's objections to the charges on the basis of double jeopardy, U.S. Constitutional Amendment V, and the appellate court affirmed. 

DISCUSSION

• The court reversed the decision of the appellate court. 
• The court held that auto theft and joyriding were a greater and lesser included offense under Ohio law, and constituted the same offense for purposes of the double jeopardy clause, U.S. Constitutional Amendment V. 
• The court held that the violations arose out of the same offense because the required proof of the same set of facts, and the successive prosecution was prohibited. 
• The court held that the prosecution could not allege two separate offenses under applicable Ohio law simply because the auto theft and joyriding took place over a nine day period.

CONCLUSION

The court reversed the decision of the appellate court that determined that a subsequent prosecution of defendant for stealing an automobile after he had pleaded guilty to operating a vehicle without the owner's consent was not barred by double jeopardy. The court held that double jeopardy applied when the charges arose out of the same incident, and there was no additional proof required in the auto theft charge.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure