The Virginia Constitution provides: "That in criminal prosecutions a man . . . shall not . . . be put twice in jeopardy for the same offense." This prohibition against double jeopardy is also embodied in the United States Constitution, as well as having been established at common law. However, what constitutes the same offense has proven to be a source of difficulty when applied to a particular case.
Constitutional Law-Double Jeopardy-Misdemeanor Conviction at Preliminary Hearing Held a Bar ta Subsequent Felony Prosecution Upon Double Jeopardy Principlus,
U. Rich. L. Rev.
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