Snell v. United States

Background

A defendant was originally charged with attempted extortion and conspiracy to commit bank robbery and was convicted on both counts. On appeal, the court upheld the conspiracy conviction but reversed the attempted extortion conviction because the conduct fell within the bank-robbery statute. A second indictment then charged attempted bank robbery arising from the same transaction. The District Court dismissed that second indictment on double jeopardy and due process grounds, but the Court of Appeals reversed and ordered a new trial, and the defendant was later convicted of attempted bank robbery.

Reasoning

The central question was whether the government could prosecute the later attempted bank-robbery charge after the earlier proceedings that grew out of the same transaction. The Supreme Court declined to review the case, so it did not issue a majority opinion resolving the double jeopardy question. Because the Court refused review, the lower-court rulings that allowed the second prosecution and the resulting conviction remain in place for this defendant.

Real world impact

By declining to hear the appeal, the Court left the appeals court’s decision and the defendant’s attempted bank-robbery conviction intact. The Supreme Court did not settle, in this opinion, the broader legal question about prosecuting multiple charges from a single transaction.

Dissents or concurrances

Justice Brennan, joined by Justice Marshall, dissented, arguing the Double Jeopardy Clause—applied to the States through the Fourteenth Amendment—should bar prosecution of all charges arising from a single criminal transaction and that the Court should have granted review and reversed.