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He at present serves as the Chair of the Association of Study Libraries' Investigation and Analytics Committee for the association's October 2018-September 2019 small business year. Against this backdrop, it is unsurprising that the Court maintained course — and that Gamble’s originalism further entrenched a doctrine much better justified and attacked structurally. Justice Marshall made this point arguing against the doctrine’s application to prosecutions by two states. He noted that, unlike the “complementary” issues of the federal government and states, id., “the sovereign issues with whose vindication each State has been charged are identical,” id. at 101. 801, 814–15 (“he dual sovereignty doctrine does not exist independent of the double jeopardy clause rather, the doctrine is derivative of it.” Id. at 814.). These rights “stemm from the ‘common-law pleas of auterfoits acquit and auterfoits convict .’” Id. (quoting Grady v. Corbin, 495 U.S. 508, 530 (Scalia, J., dissenting)).
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