Tuesday, November 5, 2013

Heath v. Alabama case brief

Heath v. Alabama case brief summary
474 U.S. 82 (1985)

Petitioner challenged a judgment of the Supreme Court of Alabama, which affirmed petitioner's conviction for kidnapping and murder.

Petitioner hired two men to kill his wife. They kidnapped petitioner's wife from her home in Alabama and drove a short distance to Georgia where they killed her. Petitioner was charged with murder in Georgia and pled guilty. He was sentenced to life imprisonment. Alabama charged petitioner with murder during kidnapping, and he was tried, convicted, and sentenced to death despite his protests of double jeopardy. After exhausting his state appeals, petitioner filed a petition for writ of certiorari raising double jeopardy claims, but no due process objections were asserted.

  • The Court granted certiorari limited to the question whether petitioner's Alabama conviction was barred by the double jeopardy clause of the U.S. Constitutional Amendment V. 
  • The Court held that a single act constituted an offense against each sovereign whose laws are violated by that act and, accordingly, each state was permitted to prosecute. 
  • The judgment of the appellate court, which affirmed the conviction, was affirmed.


The Court affirmed the judgment of the appellate court, which applied the dual sovereignty doctrine and held that prosecutions under the laws of separate sovereigns did not, for double jeopardy purposes, improperly subject an accused twice to prosecutions for the same offense.

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

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