Professor Western wrote "Death and Double Jeopardy" for a January, 1981, issue of Res Gestae, the Michigan Law School student newspaper. The subject of the article, Bullington v. Missouri, was argued to the U.S. Supreme on Jan 14, 1981. The Supreme Court has since decided Bullington, holding on May 4, 1981, that the defendant could not be sentenced to death following his earlier sentence of life imprisonment.
Death & Double Jeopardy,
Law Quadrangle (formerly Law Quad Notes)
Available at: https://repository.law.umich.edu/lqnotes/vol25/iss3/7