MOTION FOR LEAVE TO FILE
BRIEFPursuant to Rule 37.2(b), Constitutional Accountability Center, by and through undersignedcounsel, respectfully moves for leave to file thisbrief
in support of the Petition for aWrit of Certiorari. Counsel for Petitioner, SriSrinivasan, has consented to the filing of this brief;counsel for Respondent, Steven Owens of the Clark
County District Attorney‟s Office, has withheld
Constitutional Accountability Center(CAC) has an interest in this case as anorganization dedicated to fulfilling the progressive
promise of our Constitution‟s text and history.
Assuch an organization, CAC has an interest insafeguarding the constitutional right not to beplaced twice in jeopardy of life or limb for the samecrime and ensuring the integrity of the jury as aconstitutional bulwark of liberty. CAC has alreadyfiled an
brief in support of the Petition for aWrit of Certiorari in
Blueford v. Arkansas
, (No. 10-1320), which raises questions similar to thisPetition with respect to the guilt phase of acriminal proceeding.
has an interest inensuring that double-jeopardy protections aremaintained in the capital sentencing context aswell. CAC regularly provides
support tothis Court to detail relevant constitutional text andhistory,
McDonald v. City of Chicago
, 130S.Ct. 3020, 3030, 3033 n.9 (2010) (citing
brief filed by CAC on behalf of esteemedconstitutional law professors).