The purpose of this note is to emphasize that while the dual sovereignty doctrine is legally sound in its application to successive prosecutions by different states, care must be taken to prevent abuse of the doctrine. This note proposes that individual states develop consistent policies to deal with the unique situation in which the facts of the case allow for the possibility of successive prosecutions. By doing this, the states can assure that the operation of the doctrine will not result in an injustice to the defendant.
Clifton Walker Homesley, The Dual Sovereignty Doctrine Extended to Successive State Prosecutions - Heath v. Alabama, 8 Campbell L. Rev. 361 (1986).