Chase v. Oklahoma
Headline: Court declines to review a man’s claim that separate trials for kidnapping and later possessing a deputy’s gun violated his protection against being tried twice, leaving both convictions and sentences in place.
Holding: The Court declined to review the claim that separate prosecutions for using a deputy’s gun during a kidnapping violated the man’s protection against being tried twice, so both convictions and sentences remained.
- Leaves two separate prison terms in place for the same series of events.
- Allows the State to prosecute related offenses in separate trials arising from one episode.
- Denial prevents Supreme Court review that could have merged charges into a single trial.
Summary
Background
A man was stopped by Deputy Sheriff James Leland Johnston for driving on the wrong side of the road. The man and his passengers overpowered the deputy, took his .38-caliber service revolver, and forced the deputy to drive to two houses where he was kicked and beaten. The man released the deputy after taking the deputy’s wallet. He was tried and convicted in Muskogee County of kidnaping for extortion and sentenced to 35 years. The State later brought separate charges for the man’s possession of the deputy’s revolver. After a second jury trial in Tulsa County, he was convicted of carrying a firearm after a former felony conviction and sentenced to 10 years, later reduced by the Oklahoma Court of Criminal Appeals to five years, which otherwise affirmed the conviction and rejected the double-jeopardy claim (509 P.2d 171 (1973)). The Supreme Court declined to review (certiorari denied).
Reasoning
The key question was whether the State violated the man’s constitutional protection against being tried twice by prosecuting related charges in separate trials for the same episode. Justice Brennan, joined by Justices Douglas and Marshall, wrote a dissent arguing that the Double Jeopardy Clause applies to the States and generally requires joining all charges from a single act or episode in one trial. He said the circumstances here were not among the “extremely limited” exceptions that would allow separate prosecutions, and he would have granted review and reversed the separate firearms conviction.
Real world impact
Because the Court declined to hear the case, both convictions and their sentences remain in effect for this man. The result shows a State prosecuting related offenses in separate proceedings and leaves the combined imprisonment intact. The dissent warns that allowing separate prosecutions in such cases can expose defendants to multiple trials for the same course of conduct.
Dissents or concurrances
Justice Brennan’s dissent, joined by two colleagues, provides the main statement of disagreement and explains the legal basis for reversing the second conviction.
Opinions in this case:
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