Whalen v. United States

445 U.S. 684·1980

What the Court Decided

Held that the Double Jeopardy Clause bars cumulative punishments for greater and lesser-included offenses absent a clear indication that the legislature intended to authorize them.

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Cited In

Barrett v. United States

2025 Term · 24-5774

Established that the Blockburger presumption requires 'special authorization' from Congress to impose cumulative punishments for the same offense. Petitioner relies on its reasoning about lesser-included offenses in the rape/felony-murder context.