Gamble v. United States

Terance Martez Gamble was convicted in Alabama state court for being a felon in possession of a firearm. Subsequently, federal prosecutors charged him for the same instance of firearm possession under federal law. Gamble argued this sequential prosecution violated the Double Jeopardy Clause of the Fifth Amendment, which prohibits being tried twice for the same offense. The District Court and the Eleventh Circuit rejected his claim based on the dual-sovereignty doctrine, which holds that state and federal governments are separate sovereigns. The Supreme Court granted certiorari to decide whether this longstanding doctrine should be overturned.

The Supreme Court affirmed the lower courts' decisions in a 7-2 ruling. Justice Samuel Alito wrote the majority opinion, holding that under the dual-sovereignty doctrine, a state and the federal government are separate sovereigns. Consequently, an offense against both is an offense against two distinct entities, not the same offense for double jeopardy purposes. Justice Ruth Bader Ginsburg and Justice Neil Gorsuch dissented.

Whether the Double Jeopardy Clause of the Fifth Amendment prohibits a state prosecution and a subsequent federal prosecution for the same criminal conduct under the separate sovereigns doctrine.

The decision preserved the federal government's ability to bring successive prosecutions for the same conduct, significantly impacting areas like civil rights violations, gun crimes, and complex financial fraud where state and federal laws overlap. While affirming a fundamental principle of federalism, the ruling also sustained public debate over potential prosecutorial overreach and the fairness of subjecting individuals to multiple punishments for a single act.