Page 21 of 42 103 Minn. L. Rev. 844, *886 federal enforcement practice, but this is less common.) !*4 State prosecutors’ decisions, at least for certain categories of serious wrongdoing, face de facto review by federal executive officials. Or so the law for a century has permitted. The constitutional double jeopardy doctrine since at least 1922 has recognized the "dual sovereignty" of state and federal governments. Notwithstanding the guarantee that no person shall "be subject for the same offence to be twice put in jeopardy," the Double Jeopardy Clause has been understood not to preclude federal prosecutors' power to charge a person who has previously been prosecuted by state officials for the same criminal conduct, and federal prosecutions likewise do not limit subsequent state enforcement efforts. !5° By granting certiorari in United States v. Gamble this term, '°° the U.S. Supreme Court is set to revisit this doctrine, which provides the foundation for the federalism-based check on underenforcement. Federal prosecutors do not attempt to keep an eye on all state prosecution decisions and practices, and federal criminal [*887] law is not fully coextensive with state criminal law; significant gaps are discussed in the next Part. But the substantive redundancy is considerable. For some areas of dual authority - such as drug crimes, fraud, child pornography, and human trafficking - federal and state agencies often coordinate investigative efforts and divide up prosecution responsibilities. But federal Justice Department policy to exercise oversight of state enforcement practices in certain categories of crime is deliberate and formalized. Notable examples include state and local government corruption, excessive use of force and other wrongdoing by police, and other criminal civil rights violations. '!37 Especially in these areas, federal prosecutors assess whether to file their own charges in cases in which their state counterparts declined to charge, charged too len