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Columbia Law Review

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In certain circumstances, federal district court judges impose criminal sentences that are required to be consecutive to yet-to-be-imposed state criminal sentences, including those state sentences that may, in fact, never be imposed. The federal courts of appeals are divided as to whether such sentences are statutorily authorized under the applicable provision, 18 U.S.C. § 3584(a). This Note argues that the sentences are not authorized under the statute, and further, that the sentences infringe on states' and defendants' rights.



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