U.S. v. Keller, No. 94-1394, No. 936 (2nd Cir.) (58 F.3d 884) (July 7, 1995) (Judge Richard J. Cardamone)
Included in this multi-issue decision is a discussion of the meaning of the term "related" for purposes of § 4A1.2(a)(2). The Guidelines say that prior convictions are considered related if, inter alia, they were consolidated for trial or sentencing. This case holds that "simply because the same court imposes concurrent …
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