In Department of Revenue v. Kurth Ranch, the United States Supreme Court found the enforcement of a Montana statute taxing the possession of illegal drugs violated the Double Jeopardy Clause of the sixth amendment.' Kurth is the third case in what appears to be an increasingly broad interpretation of the clause. This note examines the Court's analysis and questions the necessity of protecting against successive punishments.
Eric Michael Anielak,
Double Jeopardy: Protection against Multiple Punishments,
61 Mo. L. Rev.
Available at: https://scholarship.law.missouri.edu/mlr/vol61/iss1/12