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Heath v. Alabama

United States Supreme Court
 474 U.S. 82 (1985)


Facts

Heath (plaintiff) hired two men to kill his wife. The men kidnapped Heath’s wife, Rebecca, from their Alabama home. Her body was found in Georgia. The time of death indicated that she was murdered in Georgia. A Georgia trial court charged Heath with “malice” murder. He pled guilty in exchange for a life sentence. Alabama then indicted Heath on capital murder charges. Heath pled autrefois convict arguing that his Georgia conviction for the same conduct barred the Alabama prosecution and that the court had no jurisdiction because the crime did not happen in Alabama. The Alabama court dismissed both of Heath’s claims. The court held that double jeopardy did not prohibit two states from prosecuting a defendant for the same conduct and the fact that the kidnapping commenced in Alabama made jurisdiction proper. Heath was convicted of the murder and kidnapping charges and sentenced to death. His conviction was affirmed on appeal. The Alabama Supreme Court granted certiorari solely on the double jeopardy issue and again affirmed his conviction. The Court applied the dual sovereignty doctrine which states that if a defendant’s conduct violates the laws of two separate sovereigns, then two separate crimes were committed for double jeopardy purposes. Heath petitioned the United States Supreme Court for certiorari. The Court granted certiorari as to the double jeopardy issue.

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Holding and Reasoning (O’Connor, J.)

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Dissent (Marshall, J.)

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