United States v. Ramon, 958 F.3d 919 (10th Cir. 2020). Title 18 section 3584(a) prevents a court from ordering its sentence to run consecutively to a later federal sentence. The later-sentencing court (in the context of two federal sentencings) determines whether multiple federal sentences will run consecutively or concurrently. The error here was not plain; neither the Supreme Court nor the Tenth Circuit had previously ruled on this issue.
United States v. Clark, 981 F.3d 1154 (10th Cir. 2020). The court failed to explain adequately the reasons for an 84-month sentence in an Indian-country child neglect case where there was no analogous guideline to provide a sentencing range.