The following excerpt is from United States v. Smith, No. 16-2685-cr (2nd Cir. 2017):
Some of our sister circuits have identified plain error in a district court's failure to pronounce sentence on each count. See United States v. Ward, 626 F.3d 179, 184-85 (3d Cir. 2010) ("[T]he District Court erred by failing to impose a sentence on each count, and that error is plain."); United States v. Moriarty, 429 F.3d 1012, 1025 (11th Cir. 2005) (finding district court's imposition of a 20-year general sentence on multiple counts to be plain error where that sentence exceeded 10-year statutory maximum on one of counts).
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