criminal conduct, and federal prosecutions likewise do not limit subsequent state enforcement efforts. !5° By granting certiorari in United States v. Gamble 136 this term, the U.S. Supreme Court is set to revisit this doctrine, which provides the foundation for the federalism-based check on underenforc

the long-standing principle that the prohibition against double jeopardy does not apply to prosecutions brought by different sovereigns. See, e.g., Gamble v. United States, 587 U.S. ___, 139 S. Ct. 1960, 1966-67 (2019) (and cases cited therein); Abbate v. United States, 359 U.S. 187, 195 (1959) (and c