435 U.S. 313 (1978)
United States v. Wheeler is a landmark Supreme Court case that addressed the complex intersection between tribal sovereignty and federal constitutional protections.
Does the Double Jeopardy Clause of the Fifth Amendment bar a federal prosecution after a tribal prosecution for the same act?
The Double Jeopardy Clause prohibits any individual from being tried twice 'for the same offense.' However, because tribes are separate sovereigns, offenses are not considered the same under the Double Jeopardy Clause when prosecuted by both a tribe and the federal government.
The Supreme Court held that the Double Jeopardy Clause does not bar a federal prosecution following a tribal prosecution because tribes and the federal government are separate sovereigns.
United States v. Wheeler is significant because it underscores the dual sovereignty doctrine, emphasizing that Native American tribes possess inherent sovereign authority. This autonomy includes prosecuting members under tribal law independently of federal jurisdiction. For law students, understanding this decision is vital for grasping the principles of tribal sovereignty and how they coexist with federal constitutional protections such as the Double Jeopardy Clause.