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In the United States, even if any of the states were to eliminate the merger doctrine, a conviction for both an offense and any of its lesser-included offenses, not tried in the same case, might be found to be prohibited by the Double Jeopardy Clause of the Fifth Amendment to the Constitution as interpreted by the U.S. Supreme Court in Blockburger v. United States, 284 U.S. 299 (1932).