Terance Gamble v. United States of America

In 2015, Terance Gamble was pulled over in Alabama for a traffic violation, where officers discovered a handgun. As a convicted felon, he was charged and convicted under Alabama state law for illegal firearm possession. Subsequently, federal prosecutors charged him for the same act under federal law. Gamble moved to dismiss the federal indictment on double jeopardy grounds, arguing he had already been punished for the same offense. The district court and the Eleventh Circuit rejected his claim based on the "dual sovereignty" doctrine, which treats state and federal governments as separate sovereigns allowed to independently prosecute the same crime. The Supreme Court agreed to hear the case to determine whether the Fifth Amendment's Double Jeopardy Clause prohibits sequential prosecutions by separate sovereigns.

In a 7-2 decision issued on June 17, 2019, the Supreme Court upheld the dual sovereignty doctrine. Justice Samuel Alito, writing for the majority, declined to overrule the 170-year-old precedent, stating that the Double Jeopardy Clause protects against prosecution by a single sovereign, but distinct sovereigns may pursue their own interests independently. Justices Ruth Bader Ginsburg and Neil Gorsuch dissented, arguing the doctrine undermines individual liberty and allows prosecutorial overreach.

The central dispute was whether the Fifth Amendment's Double Jeopardy Clause should be interpreted to overturn the longstanding "dual sovereignty" doctrine, which permits a state and the federal government to separately prosecute an individual for the same criminal act without violating the constitutional prohibition on double jeopardy.

The ruling reinforced federalism but drew sharp criticism for allowing potential government harassment through successive prosecutions. It had immediate political implications, clarifying that a presidential pardon for federal crimes does not preclude state-level prosecutions for the same conduct, a significant factor in debates surrounding the limits of executive clemency. The decision ensured that the door remained open for state charges in high-profile federal investigations.