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![handle is hein.preview/prvwtcheawzs0001 and id is 1 raw text is:
No. 17-646
]n tje 6upreme Court of tje Unitch *tates
TERANCE MARTEz GAMBLE, PETITIONER
V.
UNITED STATES OF AMERICA
ON PETITION FOR A WRIT OF CERTIORARI
TO THE UNITED STATES COURT OF APPEALS
FOR THE ELEVENTH CIRCUIT
REPLY IN SUPPORT OF MOTION FOR LEAVE TO PARTICIPATE IN ORAL ARGUMENT
AND FOR EXPANDED ARGUMENT
The Court should grant the motion for the amici States to participate in oral argument
in this important case concerning whether nearly two centuries of precedent should be over-
turned. None of petitioner's contrary arguments counsels against the Court hearing from
the broad and diverse group of 36 States whose sovereignty petitioner blithely attacks.
1. Petitioner first argues that, because this case involves a subsequent federal prose-
cution, the States' interests are not implicated. But petitioner's own merits briefing insists
that the opposite is true. The question presented-as drafted by petitioner-asks
[w]hether the Court should overrule the 'separate sovereigns' exception to the Double
Jeopardy Clause. Pet. Br. i; Pet. i. That formulation does not limit the Court's analysis to
a subsequent federal prosecution. To the contrary, petitioner's brief repeatedly attacks du-
plicative prosecutions. See Pet. Br. 3; accord Pet. Br. 6, 36, 43, 45. Petitioner's brief never
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