Blockburger v. United States
United States Supreme Court
284 U.S. 299 (1932)
Blockburger (defendant) was convicted on multiple counts under the Harrison Narcotic Act: one for selling morphine, one for selling morphine not in the original stamped package to the same buyer the next day, and one for making that second sale without a written order from the buyer. He argued the two sales to the same person a day apart were really one offense, and that selling outside the original package and selling without a written order were really the same crime because both appeared in the same statute. The court of appeals affirmed his convictions.
Whether a defendant is wrongly convicted multiple times for the same offense when each act is separately prohibited by statute and each charged offense requires proof of a different element.