This section contains the nature of the case and procedural background.

Carroll (D) was arrested for starting a fire at Jefferson School. The arresting officer conducted a routine search and found a canister which was believed to be a container of nasal spray. After being booked for attempted criminal property damage, the canister was discovered again and found to contain mace. D was charged with possession of a noxious substance. D was acquitted on the possession charge. D was then brought to trial on the property damage charge. The trial court dismissed the charges because D had been prosecuted previously for the possession charge, an offense arising from the same criminal episode. The State (P) appealed.

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