Experts say the New York State Court of Appeals’ quiet denial last week of the Manhattan district attorney’s application for leave to appeal in the case of Paul Manafort, former President Donald Trump’s onetime campaign chairman, was not surprising, but a 2019 change in New York law is likely to affect other recent recipients of Trump pardons.

Trump pardoned Manafort, who was convicted on federal fraud charges in 2018, in December. By that point, two levels of New York courts had already found that the state case would put him in double jeopardy.