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Keywords

defendantappealpleawillmisdemeanordouble jeopardygrand jury
defendantappealpleawilldouble jeopardyrespondentwrit of prohibition

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Grady v. Corbin, 495 U.S. 508, 110 S.Ct. 2084, 109 L.Ed.2d 548, 58 USLW 4599

Facts

On October 3, 1987, Thomas Corbin drove his car across the median on a New York highway, resulting in a fatal accident that killed Brenda Dirago and injured her husband. Corbin was issued two traffic tickets for driving while intoxicated and failing to keep right, to which he pleaded guilty without the judge being informed of the fatality. Later, a grand jury indicted him for more serious charges, including reckless manslaughter, based on the same conduct for which he had already been convicted.

At approximately 6:35 p.m. on October 3, 1987, respondent Thomas Corbin drove his automobile across the double yellow line of Route 55 in LaGrange, New York, striking two oncoming vehicles.

Issue

Does the Double Jeopardy Clause bar a subsequent prosecution for homicide and assault when the state intends to prove conduct that constitutes offenses for which the defendant has already been prosecuted?

The Double Jeopardy Clause bars a subsequent prosecution if, to establish an essential element of an offense charged in that prosecution, the government will prove conduct that constitutes an offense for which the defendant has already been prosecuted.

Rule

The Double Jeopardy Clause bars a subsequent prosecution if, to establish an essential element of an offense charged in that prosecution, the government will prove conduct that constitutes an offense for which the defendant has already been prosecuted.

We hold that the Double Jeopardy Clause bars a subsequent prosecution if, to establish an essential element of an offense charged in that prosecution, the government will prove conduct that constitutes an offense for which the defendant has already been prosecuted.

Analysis

The court applied the Double Jeopardy Clause by examining the state's bill of particulars, which indicated that the prosecution would rely on the same conduct for which Corbin had already been convicted—specifically, driving while intoxicated and failing to keep right. This reliance on previously established conduct to prove essential elements of the new charges violated the protections afforded by the Double Jeopardy Clause.

By its own pleadings, the State has admitted that it will prove the entirety of the conduct for which Corbin was convicted—driving while intoxicated and failing to keep right of the median—to establish essential elements of the homicide and assault offenses.

Conclusion

The New York Court of Appeals affirmed the prohibition of the prosecution for reckless manslaughter, criminally negligent homicide, and third-degree reckless assault based on the Double Jeopardy Clause.

The Double Jeopardy Clause bars this successive prosecution, and the New York Court of Appeals properly granted respondent's petition for a writ of prohibition.

Who won?

Thomas Corbin prevailed in the case because the court found that the state could not prosecute him for the new charges without violating the Double Jeopardy Clause, as it would require proving conduct already adjudicated in the prior misdemeanor convictions.

The court prohibited prosecution of the driving while intoxicated counts pursuant to New York's statutory double jeopardy provision, N.Y.Crim.Proc.Law § 40.20.

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