United States v. Dixon

Alvin Dixon (defendant), on bond for murder with a condition not to commit any crime, was later held in criminal contempt for possessing cocaine with intent to distribute in violation of that condition; he then argued double jeopardy barred a separate drug prosecution, and the trial court agreed. Separately, Michael Foster (defendant) was held in contempt multiple times for violating a civil protection order barring abuse of his wife, including being found guilty of two assaults; he was later indicted on five separate counts arising from the same conduct, and argued double jeopardy and collateral estoppel barred all of them. The consolidated court of appeals held, based on Grady v. Corbin's "same-conduct" test, that double jeopardy barred both Dixon's and Foster's later prosecutions entirely. The Supreme Court granted certiorari.