The following excerpt is from U.S. v. Squires, 983 F.2d 1080 (9th Cir. 1992):
"Prior sentences imposed in related cases are to be treated as one sentence...." U.S.S.G. 4A1.2; accord United States v. Smith, No. 91-50029, slip op. 14241, 14253 (9th Cir. Dec. 9, 1992); United States v. Bachiero, 969 F.2d 733, 734 (9th Cir.1992). "[P]rior sentences are considered related if they ... were consolidated for trial or sentencing." U.S.S.G. 4A1.2, comment. (n. 3). We have recently held that a defendant's prior sentences were "related" where she was sentenced to identical concurrent sentences by the same judge at a single hearing. See Bachiero, 969 F.2d at 734; cf. Smith, No. 91-50029, slip op. at 14253-54 (defendant's prior sentences were "unrelated" where he was sentenced to consecutive sentences by the same judge at a single hearing).
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.