Article Title

Multiple Punishments for the Same Offense: The Analysis After Missouri v. Hunter or Don Quixote, the Sargasso Sea, and the Gordian Knot

Publication Title

Washington University Law Quarterly


This Article will trace the development of the multiple punishment doctrine. It will examine the doctrine as it existed prior to Sours v. State, the conflict engendered by Sours, and three important Supreme Court multiple punishment cases decided after Sours. Although some areas of uncertainty remain, it is this author's position that the multiple punishment doctrine now has a coherent theoretical basis.