In Brown v. Ohio, 432 U.S. 161 (1977), the Court reviewed a double jeopardy claim involving two prosecutions. Brown stole a vehicle in East Cleveland, Ohio and was caught driving it in Wickliffe, Ohio. He was charged with joyriding in Wickliffe, pled guilty, and was sentenced to a fine and thirty days in jail. Upon his release from jail, he returned to East Cleveland to face charges of auto theft and joyriding, resulting from the same incident. Brown objected on grounds of "former jeopardy," but pled guilty to the auto theft charge with the understanding that the trial court would consider his former jeopardy claim on a motion to withdraw his plea. Id., 432 U.S. at 163. Brown was not allowed to withdraw his plea and he appealed. Applying established double jeopardy analysis and examining the Ohio statutes, the Supreme Court reversed Brown's conviction, holding that, joyriding was a lesser included offense of the crime of auto theft and did not require proof of an additional fact which the other did not. Under these facts, the Double Jeopardy Clause barred Brown's second prosecution. The Court stated: The Double Jeopardy Clause 'protects against a second prosecution for the same offense after acquittal. It protects against a second prosecution for the same offense after conviction. And it protects against multiple punishments for the same offense.' Where consecutive sentences are imposed at a single criminal trial, the role of the constitutional guarantee is limited to assuring that the court does not exceed its legislative authorization by imposing multiple punishments for the same offense. Where successive prosecutions are at stake, the guarantee serves 'a constitutional policy of finality for the defendant's benefit.' That policy protects the accused from attempts to relitigate the facts underlying a prior acquittal, and from attempts to secure additional punishment after a prior conviction and sentence. (Id., 432 U.S. at 165-66.)