## Facts

- William Jordan Claybrooks was prosecuted in federal district court for narcotics-related conduct and received an aggregate federal sentence of 23 years’ imprisonment.
- Based on the same underlying conduct, Maryland prosecuted Claybrooks in the Circuit Court for Montgomery County on multiple state charges.
- Claybrooks was found guilty in Maryland state court and received prison terms totaling 28 years.
- The Maryland trial court ordered that 13 years of the 28-year state sentence be served consecutively to the federal sentence (i.e., those 13 years would begin after completion of the federal term).
- Claybrooks challenged the state prosecution and the consecutive structure of the state sentence on double-jeopardy grounds and then appealed after conviction and sentencing.

## Issues

1. Does the Double Jeopardy Clause bar Maryland from prosecuting and punishing a defendant for conduct that has already resulted in a federal conviction and sentence?
2. If the state prosecution is permitted, does ordering part of the state sentence to run consecutively to the federal sentence for the same conduct amount to unconstitutional multiple punishment?

## Decision

- The Court of Special Appeals of Maryland affirmed the judgments.
- The court held that a state prosecution following a federal prosecution for the same conduct is not barred by double jeopardy because the federal government and the State of Maryland are separate sovereigns.
- The court held that the state court’s decision to make 13 years of the state sentence consecutive to the federal sentence did not, by itself, violate double-jeopardy protections.

## Legal Principles

- The Double Jeopardy Clause (applied to the states through the Fourteenth Amendment) protects against a second prosecution for the same offense and multiple punishments for the same offense by the same sovereign.
- Under the dual-sovereignty doctrine, the same conduct may be prosecuted by both the federal government and a state because each sovereign may define and punish offenses against its own laws.
- A state may impose a sentence for violations of state law even when the defendant has already been sentenced federally for the same conduct; running a state sentence consecutively to a federal sentence does not itself establish a double-jeopardy violation.
- Maryland recognizes double-jeopardy protections through both constitutional doctrine and Maryland common-law tradition, but those protections do not prohibit successive federal and state prosecutions in the usual case.

## Conclusion

Claybrooks v. State held that Maryland could prosecute and sentence Claybrooks for state crimes arising from the same narcotics conduct that led to his federal conviction, and that making 13 years of the 28-year state sentence consecutive to the existing 23-year federal sentence did not violate double-jeopardy protections because the prosecutions were brought by separate sovereigns.


Claybrooks v. State, 374 A.2d 365 (1977)