The following excerpt is from Nowakowski v. People, 835 F.3d 210 (2nd Cir. 2016):
19 Additionally, we note that even where a criminal conviction is the subject of the inquiry, if the identified collateral consequences arise from separate and independent grounds from that conviction, the conviction can have no meaningful effect ... and hence cannot serve as a possible collateral consequence. Perez v. Greiner , 296 F.3d 123, 126 (2d Cir. 2002). This principle does not mean, however, that all convictions after the first (or most severe) do not have collateral consequences, if each marginally increases some risk or consequence. See Sibron , 392 U.S. at 56, 88 S.Ct. 1889.
19 Additionally, we note that even where a criminal conviction is the subject of the inquiry, if the identified collateral consequences arise from separate and independent grounds from that conviction, the conviction can have no meaningful effect ... and hence cannot serve as a possible collateral consequence. Perez v. Greiner , 296 F.3d 123, 126 (2d Cir. 2002). This principle does not mean, however, that all convictions after the first (or most severe) do not have collateral consequences, if each marginally increases some risk or consequence. See Sibron , 392 U.S. at 56, 88 S.Ct. 1889.
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