United States v. Dixon
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| United States v. Alvin Dixon and Michael Foster | ||||||||||
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| Argued December 2, 1992 Decided June 28, 1993 |
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| Holding | ||||||||||
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| Majority by: SCALIA Joined by: REHNQUIST, O'CONNOR, KENNEDY, and THOMAS |
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| Laws applied | ||||||||||
| Fifth Amendment (Protection against double jeopardy); Blockburger v. United States, 284 U.S. 299 (1932) | ||||||||||
United States v. Dixon, 509 U.S. 688 (1993) held that a criminal defendant cannot be subsequently prosecuted for a new criminal offense when the same offense already had been used to adjudicate him guilty of contempt of court. In its rationale, the Court applied the Blockbuger "same elements test," and overruled the "same-conduct" test the Court had promulgated just three years previously regarding double jeopardy in Grady v. Corbin, 495 U.S. 508 (1990).
[edit] Facts and Procedural History
Alvin Dixon had been arrested for second degree murder in the District of Columbia and subsequently posted bond. As a condition of his release, the trial court ordered the defendant not to commit any "new criminal offense." Dixon was arrested and later indicted for possession of cocaine with the intent to distribute while still awaiting trial for the murder charge. The trial court held a hearing on contempt of court for violating the "new offense" terms of his pretrial release and adjudicated him guilty of contempt. The defendant then moved to dismiss the indictment for the underlying offense of possession of cocaine on double jeopardy grounds. The trial court then dismissed the indictment. The Government then appealed to the District of Columbia Court of Appeals, which upheld the dismissal, citing Grady, (supra). The Government then appealed in a writ of certioari to the United States Supreme Court.
[edit] Rationale
In its opinion the Court returned to the simple and straightforward "same elements" test of Blockburger. The Court also overruled Grady, stating that it was based upon faulty historical grounds, and was "not only wrong in principle; it has already proved unstable in application." Dixon at 697.
