Erik Sanchez v. Terry Jacques, Warden
IN ORCDER FOR THE SENTENCING COURT TO DEPART
FROM THE CONCURCENT SENTENCES REQUIREMENT
IN .R.S. S18-1-HOB(3) DOES COOVECNMENT
MUST ENTER FACTUAL BASIS TD SUPPORT
CONSECUTVE SENTENCES AND DUES DEFENDANT
MUST PLEA CULTY TO SUCH FACTS THE
PUNISHMENT BEFORE THE CONSECUTUVE SENTENCES
MAYbE IMPOSED
MAT DeFeNSANT Be ReGNIRed tr SERVe AN
FOr STATE CRUME F VEHCULAR LUDING CANDUCT IN
WHIch DeFeNdANT HAs NEVER
Plead Guctty
0
Suck Factual BAsIs During
CHe Ccum. P. Rule 11
IN PRISBNMENT BASEd IN SUCH MATERLAL FACTS
IN
dISPUTE ABOUT AN AdDCTiONAL VeHICUlAR ELUDiNg
CriMe CuAL CoUrT HAS MADe eSSENTAL t HE
DEFENDANT's CONSECUTIVE SeNTENCE : WHIC ARe
and DeFendant s FederAlly Protected
18-1-408(3)
RIGHTS AMD LAWS G IS AN UNLAWFUL GENTENCE IN
WHICH SHLd Be COCceCTed AT ANy IME REGADLESS
IF ANy procedurAL DefAulT Alleged
Whether the sentencing court must enter a factual basis to support a consecutive sentence when a defendant has never pled guilty to such facts, depriving the defendant of due process and the right to confront such facts