Currently the Court rigidly adheres to the rule and rationale of its decision in Bartkus v. Illinois and Abbate v. United States. However, the changed relationship between the State and Federal governments in the age of cooperative Federal law has changed the criminal law and the process through which it is enforced. Thus, officials and agencies that formerly acted independently now provide a united front against crime. Therefore, the rule regarding successive prosecutions conflicts with the Fifth Amendment guarantee against double jeopardy. Although the dual sovereignty doctrine provides an image of independent, sovereign State and Federal governments, proponents of that doctrine cling to a fiction that completely fails to resemble reality. The consequence is cynicism regarding whether the Constitution indeed promotes justice. To resolve this problem, successive prosecutions should be barred in circumstances where cooperation between Federal and State officials indicates the presence of a single government entity and not two sovereigns. Such an approach responds to the reality of the criminal process in particular cases. Footnotes