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Heath v. Alabama
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| Heath v. Alabama | |
| Reference: 474 U.S. 82 | |
| Term: 1985 | |
| Important Dates | |
| Argued: October 9, 1985 Decided: December 3, 1985 | |
| Outcome | |
| Alabama Supreme Court affirmed | |
| Majority | |
| Sandra Day O'Connor • Warren Burger • Byron White • Harry Blackmun • Lewis Powell • William Rehnquist • John Paul Stevens | |
| Dissenting | |
| William Brennan • Thurgood Marshall | |
Heath v. Alabama is a case decided on December 3, 1985, by the United States Supreme Court holding that the Fifth Amendment Double Jeopardy Clause does not prohibit separate states from prosecuting and convicting an individual for the same crime. The case concerned whether two states (Alabama and Georgia) with jurisdiction over the same crime could both pursue criminal charges without violating the Double Jeopardy Clause of the Fifth Amendment. The Supreme Court affirmed the ruling of the Alabama Supreme Court.[1][2][3]
Why it matters: The Supreme Court's decision in this case established that the Double Jeopardy Clause of the Fifth Amendment does not prohibit two different states from separately prosecuting and convicting the same individual for a crime. To read more about the impact of Heath v. Alabama click here.
Background
Larry Gene Heath was arrested for hiring two men to kidnap and murder his pregnant wife in August 1981. His wife, Rebecca Heath, was kidnapped from her residence in Alabama and her body was later found across the state line in Georgia. Alabama and Georgia authorities cooperated and both pursued investigations. Heath was arrested in September 1981 by Georgia authorities and indicted by a grand jury in Troop County, Georgia. He pleaded guilty and was sentenced to life in prison.
Following his conviction in Georgia, he was indicted by a grand jury in Russell County, Alabama. Heath argued that Alabama did not have jurisdiction over the case and that the Double Jeopardy Clause of the Fifth Amendment prohibited Alabama from prosecuting him for a crime in which he had already been prosecuted and convicted. Heath's claims were rejected and he was convicted by an Alabama court and sentenced to the death penalty. His conviction was affirmed by the Alabama Court of Criminal Appeals and the Alabama Supreme Court. The decision was then appealed to the Supreme Court for review.[1][2][3]
Oral argument
Oral argument was held on October 9, 1985. The case was decided on December 3, 1985.[1]
Decision
The Supreme Court decided 7-2 to affirm the decision of the Alabama Supreme Court. Justice Sandra Day O'Connor delivered the opinion of the court. Justices William Brennan and Thurgood Marshall wrote dissenting opinions.[1]
Opinions
Opinion of the court
Justice Sandra Day O'Connor, writing for the court, argued that two states are permitted to prosecute and convict an individual for the same crime on the grounds of the dual sovereignty doctrine. This doctrine establishes that when an offense violates two sovereign governments, they both have the authority to punish the offense. To support this argument, O'Connor referred to the Supreme Court's opinion in Moore v. Illinois, which established the precedent of the dual sovereignty doctrine.[2]
| “ | The dual sovereignty doctrine, as originally articulated and consistently applied by this Court, compels the conclusion that successive prosecutions by two States for the same conduct are not barred by the Double Jeopardy Clause. The dual sovereignty doctrine is founded on the common law conception of crime as an offense against the sovereignty of the government. When a defendant in a single act violates the 'peace and dignity' of two sovereigns by breaking the laws of each, he has committed two distinct 'offences.' United States v. Lanza, 260 U. S. 377, 260 U. S. 382 (1922). As the Court explained in Moore v. Illinois, 14 How. 13, 55 U. S. 19 (1852), '[a]n offence, in its legal signification, means the transgression of a law.' Consequently, when the same act transgresses the laws of two sovereigns, 'it cannot be truly averred that the offender has been twice punished for the same offence, but only that by one act he has committed two offences, for each of which he is justly punishable.' [4] | ” |
| —Sandra Day O'Connor, majority opinion in Heath v. Alabama[2] | ||
O'Connor's opinion also addressed a second claim brought by the petitioner that the Supreme Court consider a balancing of interests approach to the case. O'Connor rejected this consideration, arguing that it cannot be asserted that one state's penal interests would be satisfied by another state's actions.[2]
| “ | Such a deprivation of a State's sovereign powers cannot be justified by the assertion that, under 'interest analysis,' the State's legitimate penal interests will be satisfied through a prosecution conducted by another State. A State's interest in vindicating its sovereign authority through enforcement of its laws, by definition, can never be satisfied by another State's enforcement of its own laws. Just as the Federal Government has the right to decide that a state prosecution has not vindicated a violation of the 'peace and dignity' of the Federal Government, a State must be entitled to decide that a prosecution by another State has not satisfied its legitimate sovereign interest. In recognition of this fact, the Court consistently has endorsed the principle that a single act constitutes an 'offence' against each sovereign whose laws are violated by that act. The Court has always understood the words of the Double Jeopardy Clause to reflect this fundamental principle, and we see no reason why we should reconsider that understanding today. [4] | ” |
| —Sandra Day O'Connor, majority opinion in Heath v. Alabama[2] | ||
Dissenting opinions
Justice Thurgood Marshall, in a dissenting opinion, argued that the dual sovereignty doctrine cannot be used to justify prosecuting an individual twice for the same crime by two different states.[2]
| “ | Where two States seek to prosecute the same defendant for the same crime in two separate proceedings, the justifications found in the federal-state context for an exemption from double jeopardy constraints simply do not hold. Although the two States may have opted for different policies within their assigned territorial jurisdictions, the sovereign concerns with whose vindication each State has been charged are identical. Thus, in contrast to the federal-state context, barring the second prosecution would still permit one government to act upon the broad range of sovereign concerns that have been reserved to the States by the Constitution. The compelling need in the federal-state context to subordinate double jeopardy concerns is thus considerably diminished in cases involving successive prosecutions by different States. Moreover, from the defendant's perspective, the burden of successive prosecutions cannot be justified as the quid pro quo of dual citizenship. To be sure, a refusal to extend the dual sovereignty rule to state-state prosecutions would preclude the State that has lost the 'race to the courthouse' from vindicating legitimate policies distinct from those underlying its sister State's prosecution. But, as yet, I am not persuaded that a State's desire to further a particular policy should be permitted to deprive a defendant of his constitutionally protected right not to be brought to bar more than once to answer essentially the same charges. [4] | ” |
| —Thurgood Marshall, dissenting opinion in Heath v. Alabama[2] | ||
Justice William Brennan, in a dissenting opinion, joined Marshall's dissent and clarified his opinion on the role that different interests should have in determining whether multiple prosecutions are for the same offense. To support this argument, Brennan referred to his opinion in the case Abbate v. United States, which permitted state and federal prosecutions for the same criminal act on the grounds that the prosecutions were for different purposes. Brennan commented in a separate opinion that consecutive prosecutions for the same crime at the same level of government are barred by the Fifth Amendment, regardless of the charge.[2]
| “ | I adhere to the position I took in Abbate, that the different purposes or interests served by specific statutes cannot justify an exception to our established double jeopardy law. However, I read JUSTICE MARSHALL's dissent to use 'interest' analysis in another context. He employs it to demonstrate the qualitative difference in the general nature of federal and state interests and the qualitative similarity in the nature of States' interest. JUSTICE MARSHALL's use of this interest analysis furthers, rather than undermines, the purposes of the Double Jeopardy Clause. [4] | ” |
| —William Brennan, dissenting opinion in Heath v. Alabama[2] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: State sovereignty
Heath v. Alabama established that the Double Jeopardy Clause of the Fifth Amendment does not prohibit two different states from separately prosecuting and convicting an individual for the same illegal act. The Fifth Amendment protects individuals from being prosecuted more than once for the same offense. The decision in Heath v. Alabama is guided by the dual sovereignty doctrine, which states the following:
| “ | [W]hen a defendant in a single act violates the 'peace and dignity' of two sovereigns by breaking the laws of each, he has committed two distinct 'offences' for double jeopardy purposes. In applying the doctrine, the crucial determination is whether the two entities that seek successively to prosecute a defendant for the same course of conduct can be termed separate sovereigns. This determination turns on whether the prosecuting entities' powers to undertake criminal prosecutions derive from separate and independent sources. It has been uniformly held that the States are separate sovereigns with respect to the Federal Government because each State's power to prosecute derives from its inherent sovereignty, preserved to it by the Tenth Amendment, and not from the Federal Government. [4] | ” |
| —Heath v. Alabama[2] | ||
This doctrine permits separate sovereignties to pursue the same case in criminal court when the offense committed impacts both jurisdictions. Prior to this case, the dual sovereignty doctrine had been used to authorize consecutive prosecutions at the state and federal levels. The decision in Heath v. Alabama established the precedent for multiple states to pursue consecutive prosecutions against an individual for the same crime when the offense is within multiple states' jurisdictions.[5][2]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 1.3 Oyez, "Heath v. Alabama," accessed June 9, 2022
- ↑ 2.00 2.01 2.02 2.03 2.04 2.05 2.06 2.07 2.08 2.09 2.10 2.11 Justia, "Heath v. Alabama," accessed June 9, 2022
- ↑ 3.0 3.1 LexisNexis, "Heath v. Alabama - 474 U.S. 82, 106 S. Ct. 433 (1985)," accessed June 9, 2022
- ↑ 4.0 4.1 4.2 4.3 4.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Legal Information Institute, "Dual Sovereignty Doctrine," accessed June 9, 2022
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