On Point blog, page 1 of 1
Habeas – Concurrent Sentence Doctrine
Matthew Steffes v. Thurmer, 7th Cir No. 09-3317, 11/4/11
seventh circuit decision, denying habeas relief on review of 2006AP1633-CR
The “concurrent sentence doctrine” – which “allows appellate courts to decline to review a conviction carrying a concurrent sentence when one ‘concurrent’ conviction has been found valid,” Cheeks v. Gaetz, 571 F.3d 680, 684-85 (7th Cir.2009) – doesn’t apply here in view of a separate assessment and the potential to affect parolability:
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