Heath v. Alabama

Heath (defendant) hired two men to kidnap and kill his wife, Rebecca, from their Alabama home; her body was found in Georgia, and the evidence showed she was actually killed there. Georgia charged Heath with murder, and he pleaded guilty in exchange for a life sentence. Alabama then separately indicted him on capital murder charges for the same underlying conduct. Heath argued his Georgia conviction barred the Alabama prosecution under double jeopardy, and separately argued Alabama lacked jurisdiction since the killing happened in Georgia. Alabama courts rejected both arguments, applying the dual sovereignty doctrine and finding jurisdiction proper because the kidnapping began in Alabama; Heath was convicted and sentenced to death, with his conviction affirmed on appeal. The U.S. Supreme Court granted certiorari on the double jeopardy question.