context: In support of his argument, Neto points to early cases in which the Supreme Court indicated that a Due Process analysis might apply to successive prosecutions in certain cases.
citation_a.signal: see
citation_a.parenthetical: stating that there might be "hypothetical situations in which the [Due Process Clause of] the Fourteenth Amendment might prohibit consecutive prosecutions of multiple offenses," but ultimately finding no Due Process violations on the facts
citation_a.sentence: See, e.g., Ciucci v. Illinois, 356 U.S. 571, 573, 78 S.Ct. 839, 2 L.Ed.2d 983 (1958) (per curiam) (finding no Due Process violation “upon the record as it stands,” but noting that two of the justices in the majority might have found “fundamental unfairness” if certain evidence suggesting improper prosecutorial motive were included in the record); Hoag v. New Jersey, 356 U.S. 464, 467-69, 78 S.Ct. 829, 2 L.Ed.2d 913 (1958) (stating that there might be “hypothetical situations in which the [Due Process Clause of] the Fourteenth Amendment might prohibit consecutive prosecutions of multiple offenses,” but ultimately finding no Due Process violations on the facts).
citation_b.signal: see also
citation_b.identifier: 883 F.2d 877, 881
citation_b.parenthetical: finding that separate robbery and kidnaping convictions arising out of the same incident satisfied Blockburger test, but remanding "for a consideration of the state court records in light of the due process standards for successive prosecutions contained in Hoag and Ciucci "
citation_b.sentence: See also Tucker v. Makowski, 883 F.2d 877, 881 (10th Cir. 1989) (finding that separate robbery and kidnaping convictions arising out of the same incident satisfied Blockburger test, but remanding “for a consideration of the state court records in light of the due process standards for successive prosecutions contained in Hoag and Ciucci ”).