U.S. v. Letterlough, No. 94-5571 (4th Cir.) (63 F.3d 332) (August 28, 1995) (Judge Karen J. Williams)
The Court held that district courts are required to consider (i) whether the offenses occurred in different geographic locations; (ii) whether the offenses were substantively different; and (iii) "whether the offenses involved multiple victims or multiple criminal objectives." (Id., at 335-36) These factors may be considered together or independently, and …
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