State v. Bonham
In State v. Bonham, 28 P.3d 303, 306 (Alaska App. 2001) the Court considered a dispute that is similar to the present case. Bonham was convicted of mail fraud in federal court. She contended that her federal conviction encompassed all of the misleading filings that formed the basis of her state charges of perjury and false securities reports.
In analyzing this claim, the Court noted that AS 12.20.010 did not necessarily bar all related charges arising out of the same episode or transaction.
The Court compared the elements of the federal and state offenses in light of the misconduct that was charged in each jurisdiction and concluded that Bonham's federal conviction was not for the same act charged in her state prosecution.