Heath v. Alabama Case Brief

Why is the case important?

Petitioner, Heath, sought a writ of certiorari after being convicted in Alabama on charges that he had already been convicted of in Georgia.

Facts of the case

“In August of 1981, Larry Gene Heath hired two men to kidnap and murder his pregnant wife. Heath met the men in Georgia, just across the state line from the Heath residence in Alabama, led them back to the house, and left. Rebecca Heath’s body was later found on the side of a road in Georgia. Both Georgia and Alabama authorities pursued investigations in which there was a degree of cooperation.On September 4, 1981, Georgia authorities arrested Heath, and he waived his Miranda rights and confessed. He was indicted by a grand jury in Troop County, Georgia, and pled guilty in February 10, 1982. On May 5, 1982, Heath was indicted by a grand jury in Russell County, Alabama. Prior to the trial, Heath argued that his conviction and sentencing in Georgia barred any prosecution in Alabama and that Alabama lacked jurisdiction. The trial court rejected both claims, and Heath was convicted. The Alabama Court of Appeals affirmed, as did the Alabama Supreme Court.”

Question

Whether the dual sovereignty doctrine, which allows states separate prosecutions, is barred by double jeopardy.

Answer

Successive prosecutions by two states for the same conduct are not barred by the Double Jeopardy Clause of the Fifth Amendment.

Conclusion

“The U nited States Supreme Court affirmed the conviction. It 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. Under the dual sovereignty doctrine, successive prosecutions by two states for the same conduct are not barred by the double jeopardy clause of the Fifth Amendment

  • as such, Alabama was not barred from trying the defendant for the capital offense of murder during a kidnapping after Georgia had convicted him of murder based on the same homicide.”
    • Case Brief: 1985
    • Petitioner: Larry Gene Heath
    • Respondent: Alabama
    • Decided by: Burger Court

    Citation: 474 US 82 (1985)
    Argued: Oct 9, 1985
    Decided: Dec 3, 1985