Deanna Roberts pleaded guilty in federal court to theft of a medical product that she injected into a patient, causing the patient’s death. Georgia later indicted her for state offenses arising from the same death. Roberts filed a statutory plea in bar, arguing that the federal conviction barred the state prosecution under Georgia’s successive-prosecution statute. The Georgia Supreme Court affirmed the denial of the plea. The court held that the denial of this statutory double-jeopardy claim was appealable under the collateral-order doctrine, but the statutory bar did not apply because the federal and state offenses each required proof of a fact the other did not. The court compared the elements of the offenses rather than relying on the indictment’s broader factual allegations. The State could therefore proceed with the charged state offenses.