Last November, I explained how Mueller’s team seemed to be strategizing a way to outmaneuver Trump’s pardons when they initially brought charges against Manafort. Prosecutors appeared to be holding back some charges for states to bring, just in case Trump pardoned Manafort. Presidential pardons only address federal crimes, which means Manafort could face state charges for the same acts.

Federal double jeopardy law would not be an issue here. The doctrine of dual sovereignty allows the federal and state governments to prosecute the same crimes. The problem is that many states broaden double jeopardy protections to prevent the bringing of state charges after a federal prosecution. I’ve explained in Slate that New York and Pennsylvania have such a rule. It turns out that Virginia and California do, too. But because of some likely combination of prosecutorial skill and luck, Manafort still faces prosecutions in those states, plus perhaps Illinois and others.