Gamble v. United States Case Brief Summary | Law Case Explained

Gamble v. United States | 139 S.Ct. 1960 (2019)

The Fifth Amendment’s Double Jeopardy Clause, which prohibits prosecuting a defendant twice for the same offense, seems straightforward. However, its application is frequently complicated. In Gamble versus United States, the Supreme Court considered whether to overturn nearly two centuries of precedent permitting federal and state governments to prosecute a defendant for offenses sharing common elements under their separate laws.

During a traffic stop, a police officer smelled marijuana coming from Terance Gamble’s car. The officer searched Gamble’s vehicle and found a loaded handgun. Based on his prior robbery conviction, Gamble was charged with possessing a firearm as a felon in violation of Alabama law. After being convicted of that offense in state court, Gamble was indicted for the same incident under a federal law, which also prohibited felons from possessing firearms. Gamble filed a motion to dismiss, arguing that his state conviction and the federal indictment were for the same offense, exposing him to double jeopardy in violation of the Fifth Amendment. The district court denied Gamble’s motion, ruling that under the dual sovereignty doctrine, two offenses sharing common elements prosecuted by two different sovereigns aren’t the same offense for double jeopardy purposes. Gamble subsequently pleaded guilty to the federal charge but appealed his double jeopardy challenge to the Eleventh Circuit, which affirmed the district court’s ruling. The United States Supreme Court granted cert to determine whether to overturn the dual sovereignty doctrine.

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