Manigault v. State

MOYLAN, Judge.

As we try to honor the Double Jeopardy Clause’s prohibition against multiple punishment for “the same offense,” multiple indictments pose problems in terms of adding up the legitimate units of permitted prosecution. A single multi-count indictment poses similar problems. The potential problems, however, increase exponentially when we encounter multiple multi-count indictments.

The appellant, Arnold Manigault, went to trial before a Baltimore City jury on multiple multi-count indictments. He was indisputably guilty of perpetrating assaults, in the course of a single criminal…