Habeas, Sentencing
In de novo resentencing subsequent to a successful collateral challenge to the conviction, the court may consider convictions after the initial sentencing when compiling the criminal history of the deft.
Dissent: facts are muddled here -- AUSA incorrectly described relationship between the two sentences.
United States v. Quentin Tidwell
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.