In Rinaldi v. United States (1977), the Supreme Court ruled in favor of defendant Joseph Rinaldi, who had been convicted for counterfeiting and conspiracy to counterfeit federal reserve notes. The court held that the government's decision to prosecute Rinaldi in both state and federal courts violated a policy established by the Department of Justice aimed at preventing dual prosecutions for substantially identical offenses arising from the same criminal episode. This policy was intended to protect defendants from harassment or undue strain on their resources due to multiple prosecutions for essentially the same crime. Despite this ruling, it is important to note that this case did not establish a constitutional prohibition against double jeopardy; rather, it affirmed an internal departmental guideline within the Department of Justice designed with similar principles in mind.

In the dissenting opinion for Rinaldi v. United States, Justice Rehnquist argued that the majority's decision to dismiss an indictment due to prosecutorial vindictiveness was unwarranted and set a dangerous precedent. He contended that there was no evidence of actual vindictiveness by prosecutors in this case; instead, they were merely pursuing charges based on new information obtained after the initial trial. Furthermore, he expressed concern about how this ruling could potentially deter prosecutors from seeking justice out of fear of being accused of vindictiveness. In his view, it is not unusual or improper for a prosecutor to pursue additional charges if new evidence comes to light after an initial trial has concluded.