In the 

United States Court of Appeals 

For the Seventh Circuit ____________________ 

No. 13-1812 

UNITED STATES OF AMERICA, 

Plaintiff-Appellee, 

v.

DAVID VANCE, 

Defendant-Appellant. 

____________________ 

Appeal from the United States District Court for the 

Northern District of Illinois, Eastern Division. 

No. 7 CR 351–2 — Joan B. Gottschall, Judge. 

____________________ 

ARGUED MAY 22, 2014 — DECIDED AUGUST 19, 2014 

____________________ 

Before POSNER, FLAUM, and MANION, Circuit Judges. 

POSNER, Circuit Judge. David Vance, along with Alton 

Marshall and Henry Bluford, were charged with having 

committed two bank robberies in Chicago in 2007, 18 U.S.C. 

§ 2113(a), as well as related crimes, such as conspiring to rob 

the banks. 18 U.S.C. § 371. Vance also was charged with the 

more serious offense of killing a person during the commission of a bank robbery. 18 U.S.C. § 2113(e). 
2 No. 13-1812 

Marshall and Bluford, but not Vance, pleaded guilty. 

Vance was tried by a jury, and Marshall testified at the trial. 

The jury convicted Vance, and the judge sentenced him to 

terms of years on all counts except the one charging the killing; for that the judge sentenced him to life in prison. The 

judge made the sentences on two of the counts—sentences to 

fixed terms of prison of 7 and 25 years, respectively—

consecutive to the sentences on all the other counts, including therefore the sentence of life imprisonment. The judge 

imposed conditions of supervised release, which of course 

do not take effect until the defendant is released. The imposition of sentences consecutive to a life sentence and of conditions of supervised release when a life sentence is imposed 

presents issues that we discuss briefly at the end of the opinion. 

Why it’s taken seven years from the indictment to the argument of the appeal is unexplained, though we can piece 

together some of the reasons from the record. Marshall and 

Bluford didn’t plead guilty till 2009; after that there probably 

was a protracted back and forth with Vance to see whether 

he would cooperate and plead guilty. Also, the parties filed 

numerous motions. The government for example moved to 

disclose grand jury testimony and the defense asked the district court for money to pay expert witnesses yet refused to 

submit a budget. The defense also twice asked the district 

judge to delay the trial. And the pre-sentencing report from 

the probation service was not submitted to the court more 

than a year after the jury had found Vance guilty, though it 

appears that the delay in submitting the report was attributable to post-trial motions rather than to any lassitude by the 

probation service. 
No. 13-1812 3 

According to Marshall’s testimony, the night before the 

first of the two bank robberies Vance suggested to him that 

they commit robberies that night. Marshall agreed, and that 

night the pair robbed a seafood restaurant, a Mexican restaurant, and a diner. They wore ski masks (the same ones used 

later in the bank robberies) and gloves. Vance carried a longbarreled .44 caliber revolver, the same model later used in 

both bank robberies. Vance told Marshall that he (Vance) 

would approach the counter to get the restaurant’s money 

while Marshall “watch[ed] his back,” and that was how they 

conducted two of the restaurant robberies. In the third, the 

robbery of the Mexican restaurant, both men approached the 

counter and ordered the employees there to open the register. 

Vance argues that Marshall’s testimony about the three 

restaurant robberies should not have been admitted; that if 

believed all it proved was that Vance had a propensity to 

commit robberies, and propensity evidence is not admissible, lest it prejudice the jurors against the defendant, causing 

them to convict even if the evidence of his guilt of the crime 

that he is being tried for is weak. 

But Rule 404(b) of the Federal Rules of Evidence, the 

source of the prohibition against introducing evidence of a 

defendant’s propensity to commit crimes, allows (in subsection (b)(2)) the admission of evidence of other crimes besides 

the one the defendant is charged with if that evidence pertains to, among other things, “identity,” in this case Vance’s 

identity as one of the masked bank robbers. Similarities between the restaurant robberies and the bank robberies supported an inference that if, as Marshall testified, Vance had 

been one of the restaurant robbers he probably had been one 
4 No. 13-1812 

of the bank robbers as well. Remember that in two of the restaurant robberies Vance had rushed the counter where the 

money was kept while Marshall watched the patrons 

(though, in the third both had rushed the counter). There 

had been a “rusher” in the bank robberies as well, and if 

Vance had been the rusher in the restaurant robberies this 

made it more likely that he had also been the rusher in the 

bank robberies—and whoever rushed the counter in the second bank robbery was also the teller’s killer. Vance brandished a .44 caliber revolver in the restaurant robberies, as 

he did in one of the bank robberies. And Marshall and Vance 

trusted each other enough as accomplices in robbery—as 

shown by their joint commission of the three restaurant robberies—to make it seem likely that Vance was also a participant in the bank robberies, to which Marshall had already 

confessed.

This body of evidence was not conclusive in identifying 

Vance as one of the bank robbers, but it was not so flimsy 

that it had to be excluded on the ground that its probative 

value was outweighed by its prejudicial effect. Weakest was 

the caliber evidence, since .44 caliber revolver ammunition is 

common. But there are a number of equally or more common calibers of such ammunition, such as .22, .32, .357. 38, 

and .45, so the fact that .44 is common does not negate an 

inference that Vance is likely to have been armed with the 

same weapon in both robberies (rather than that another of 

the robbers just happened to have a weapon of the identical 

caliber), thus increasing the likelihood that he was the killer 

in the bank robbery. Moreover, when several pieces of evidence point in the same direction, the probability that it’s the 

right direction is greater than the probability that any one of 

the pieces is accurate. Suppose the probability that the first 
No. 13-1812 5 

piece of evidence is accurate—and thus that Vance was indeed one of the bank robbers—is .50, that the probability 

that the second is accurate is .40, but that the probability that 

the third is accurate is only .10. Still, the likelihood that none 

of the evidence is accurate—and Vance therefore was not 

one of the bank robbers after all—is lower when the third 

piece of evidence is considered than when it is not; excluding it in our example would raise the probability of erroneous identification of Vance as one of the bank robbers from 

27 to 30 percent. ((1 – .5) x (1 – .4) x (1 – .1) = .27; (1 – .5) x (1 – 

.4) = .30.) 

It could be (though is not) argued that since Marshall 

was the source of the evidence of Vance’s participation in the 

restaurant robberies and also the evidence of his participation in the bank robberies, the restaurant-robberies evidence 

had no probative value; if the jury thought Marshall was telling the truth about the bank robberies, that was enough to 

nail Vance; if they disbelieved him, his testimony about the 

restaurant robberies was irrelevant because Vance wasn’t on 

trial for those robberies. But that analysis is incomplete. The 

restaurant evidence if believed showed that Marshall and 

Vance were partners in crime and thus increased the likelihood that Vance had participated in the bank robberies, 

“rushed the counter,” and shot the teller with a .44 caliber 

pistol. 

When other-crimes evidence is used for a proper purpose, such as to determine identity, rather than for the improper purpose of demonstrating that the defendant has a 

propensity to commit crimes (he committed a prior crime, so 

probably he committed the crime he’s currently accused of), 

it is important both that the proof value of the evidence not 
6 No. 13-1812 

be substantially outweighed by its prejudicial effect and that 

the jury be carefully instructed to limit its consideration to 

the effect of the evidence to determining identity. As this 

court explained in United States v. Gomez, No. 12-1104, p. 24 

(7th Cir. Aug. 18, 2014) (en banc), regarding the first of these 

requirements, the relevance of the evidence for a proper 

purpose “must be established through a chain of reasoning 

that does not rely solely on the forbidden inference that the 

person has a certain character and acted in accordance with 

that character on the occasion charged in the case. If the proponent [the prosecutor] can make this initial showing, the 

district court must in every case assess whether the probative value of the other-act evidence is substantially outweighed by the risk of unfair prejudice and may exclude the 

evidence under Rule 403 if the risk is too great. The court’s 

Rule 403 balancing should take account of the extent to 

which the non-propensity fact for which the evidence is offered actually is at issue in the case.” 

Vance’s identity as one of the bank robbers is of course at 

issue in this case, and the evidence that he was one of them 

does not depend on inferring that if he had committed robberies in the past he was likely to have committed the robbery that he was charged with in the present case. 

The judge twice gave limiting instructions, telling the jury it could not use the evidence of the restaurant robberies to 

infer that Vance had a propensity to commit crimes, specifically robberies. The need for such instructions arises from 

the danger that jurors who are given evidence of a defendant’s prior crimes will conclude from it that the defendant 

is a bad, dangerous person who should be convicted even if 

the proof that he committed the crime that he’s being tried 
No. 13-1812 7 

for is weak. The restaurant robberies showed that Vance was 

indeed a robber, seemingly a compulsive one; a jury might 

think Vance so dangerous that it should resolve any doubts 

about his guilt of the bank robberies against him rather than 

in his favor. 

 Hence the need for limiting instructions—but there are 

grounds for skepticism about their efficacy in preventing juries from reasoning in that way. Krulewitch v. United States, 

336 U.S. 440, 453 (1949) (Jackson, J., concurring) (“the naive 

assumption that prejudicial effects can be overcome by instructions to the jury all practicing lawyers know to be unmitigated fiction”); Maus v. Baker, 747 F.3d 926, 927–28 (7th 

Cir. 2014); United States v. Mazzone, 782 F.2d 757, 764 (7th Cir. 

1986); United States v. Jones, 455 F.3d 800, 811 (7th Cir. 2006) 

(concurring opinion); Nash v. United States, 54 F.2d 1006, 

1006–07 (2d Cir. 1932) (L. Hand, J.); Edith Greene & Mary 

Dodge, “The Influence of Prior Record Evidence on Juror 

Decision Making,” 19 Law & Human Behavior 67, 76–77 

(1995); Roselle L. Wissler & Michael J. Saks, “On the Inefficacy of Limiting Instructions,” 9 Law & Human Behavior 37, 

38–39 (1985). 

And the second limiting instruction, given at the end of 

this case, was murky. It stated: “You have heard evidence 

that the defendant was involved in conduct other than that 

charged in the indictment. You may consider this evidence 

only in deciding questions of defendant’s preparations or 

plans to commit the charged offenses or the identity of the 

persons involved in the charged offenses. You should consider this evidence only for these limited purposes.” As the 

government explains in a footnote to its brief, the reference 

to Vance’s other conduct included not only the restaurant 
8 No. 13-1812 

robberies but also “the car thefts [that is, the theft of the cars 

used in the bank robberies] as proof of defendant’s preparation and planning.” The judge should have separated out the 

restaurant robberies, which had nothing to do with the 

preparations for the bank robberies, from the bank robberies 

that were the subject of the trial. 

The instructions also were too abrupt, in failing to explain to the jury why it could not use the evidence to demonstrate propensity. The reason is not obvious and there is a 

danger that if given a counterintuitive command without an 

explanation a jury will ignore it. “Do this because I say so” 

may work with children but is unlikely to work with adults. 

To quote from the Gomez opinion again (at p. 26), “we see no 

reason to keep the jury in the dark about the rationale for the 

rule against propensity inferences. Lay people are capable of 

understanding the foundational principle in our system of 

justice that ‘we try cases, rather than persons.’ ... The court’s 

limiting instruction would be more effective if it told the jurors that they must not use the other-act evidence to infer 

that the defendant has a certain character and acted ‘in character’ in the present case because it does not follow from the 

defendant’s past acts that he committed the particular crime 

charged in the case. Finally, the instruction would be improved by tying the limiting principle to the prosecution’s 

burden of proof. The jurors should be reminded that the 

government’s duty is to prove beyond a reasonable doubt 

every element of the specific crime charged, and it cannot discharge its burden by inviting an inference that the defendant 

is a person whose past acts suggest a willingness or propensity to commit crimes” (emphasis in original). 
No. 13-1812 9 

None of these things was done in this case, but Vance 

does not complain about the limiting instructions and so 

there is no issue of their validity. 

Nor does he complain that the judge or the jury improperly balanced probative value and prejudicial effect. Rather 

he takes the extreme position that the evidence of the restaurant robberies had only “very small” or even zero probative 

value, mainly because Marshall testified, and Vance did not 

deny, that they were long-time friends and so the evidence 

concerning the restaurant robberies merely confirmed that 

acknowledged fact. Actually it did more; it pointed to Vance 

as the probable triggerman in the bank robbery. In all three 

restaurant robberies Vance was the robber who rushed the 

counter while Marshall watched his back (although Marshall 

did join him at the counter in one of the robberies). The fact 

that when Vance and Marshall robbed together (at least 

when they robbed together on the night before the first bank 

robbery) Vance rushed the counter makes it more likely that 

he also rushed the counter at the second bank, where the 

teller was killed; video surveillance evidence showed that 

whoever rushed the counter at the second bank shot the 

teller moments later. Furthermore, there is a difference between partnership in robberies and a personal friendship. If 

Vance and Marshall were partners in robbery, there is at 

least some likelihood that in a robbery at which Marshall is 

conceded to have been present (the bank robbery), one of the 

other robbers was indeed Vance. 

Granted, the evidence of the restaurant robberies did not 

have a great deal of probative value—but for a reason that 

does not help Vance’s defense. It had very limited incremental probative value because the other evidence of Vance’s 
10 No. 13-1812 

guilt (discussed next) was very strong. But by the same token the incremental prejudicial effect of the evidence regarding the restaurant robberies must also have been slight, because for an effect to be prejudicial means that it may actually have swayed the jury’s decision. If conviction was a forgone conclusion, the evidence of the restaurant robberies 

was icing on the cake; the government didn’t need it to convict Vance. 

The other evidence of Vance’s guilt included Marshall’s 

eyewitness testimony about the bank robberies, DNA evidence implicating Vance, the identification of Vance as one 

of the robbers by a teller at the first bank robbed and also by 

Vance’s own girlfriend, and testimony by Marshall’s girlfriend that further implicated Vance. Taken all in all, this evidence, wholly apart from the evidence about the restaurant 

robberies, was compelling. Even without that evidence, no 

reasonable jury could have acquitted Vance. 

The teller testified that she recognized Vance, whom she 

had known since childhood, as the robber who approached 

her and demanded money. Marshall’s girlfriend testified 

that Vance, Marshall, and Bluford arrived at her apartment 

the evening before the day planned for the second robbery 

(although that robbery did not actually take place for another two days) and that Vance was carrying bags of guns 

and ammunition. She also testified that Marshall had confessed to her that he had committed the second bank robbery 

along with Vance and Buford and that Vance had been “the 

man with the gun going over the counter,” and thus the killer. Vance’s girlfriend testified that she recognized him in a 

surveillance photograph taken during the first bank robbery.
No. 13-1812 11 

Vance’s counsel tries to pick apart the government’s evidence—other than that of Marshall’s girlfriend, which by itself would have been sufficient to convict Vance, since Marshall’s confession to her, made before he had cut a plea deal 

with the government in exchange for testifying against 

Vance, was recorded by the wire that the FBI had given her 

to wear. Counsel notes, however, that Marshall had lied repeatedly in his dealings with the prosecutors and claims that 

this proved him to have been a “pathological liar” none of 

whose testimony should have been believed. Counsel also 

argues that the DNA evidence should not have been admitted and that the female teller and Vance‘s girlfriend could 

not have identified him because the robber whom they identified as Vance was masked. 

The jury was entitled to reject these arguments. Regarding Marshall’s lies, falsus in uno, falsus in omnibus (false in one 

thing—or for that matter more than one thing—therefore 

false in everything) is not a doctrine of American law, United 

States v. Edwards, 581 F.3d 604, 612 (7th Cir. 2009), and isn’t 

even true. When Mary McCarthy famously said of Lillian 

Hellman “that every word she writes is a lie, including 'and' 

and 'the,’” Hellman sued her for defamation. (She died before judgment, and her estate dropped the suit, even though 

New York had abrogated the common law rule that an action for defamation does not survive the victim’s death. N.Y. 

Estates, Powers & Trusts Law § 11-3.2(b).) The jury was entitled to believe Marshall’s testimony that Vance was one of 

his accomplices in the bank robberies, as well as in the restaurant robberies, and also that Vance had admitted to him 

after the second robbery to having shot the teller who died. 
12 No. 13-1812 

Vance’s DNA was found on latex gloves near the getaway car used in the second bank robbery; and Marshall testified that the robbers had worn such gloves. Vance’s counsel complains that the police investigator put the gloves in a 

plastic bag rather than a paper bag, which is a no-no because 

such a bag traps moisture, which tends to dissolve DNA. 

E.g., National Institute of Justice, “Evidence Collection and 

Preservation,” www.ncjrs.gov/nij/DNAbro/evi.html (visited 

Aug. 7, 2014). But as the government points out, this error 

could not morph someone else’s DNA into a match for 

Vance’s; it could only make Vance’s DNA more difficult to 

find on the gloves—yet it was found, as explained by the 

government’s expert witness. Vance’s counsel complains 

that the witness should have been subjected to a Daubert

hearing. But counsel’s complaint about the DNA evidence—

that the gloves shouldn’t have been put in plastic bags—was 

of no consequence to the validity of the evidence. And it was 

the error not of this witness but of the FBI investigator who 

had found the gloves that was being challenged; the expert 

witness’s competence to match DNA taken from Vance to 

DNA found on the gloves was not in question. Furthermore, 

the judge conducted several pretrial hearings, at which hundreds of pages of reports prepared by the expert witness, 

and other relevant documents, were presented and considered. The hearings taken as a whole constituted an adequate 

Daubert hearing, albeit the expert did not testify at them. 

Vance’s counsel further complains that the expert demonstrated her incompetence by denying the possibility of 

secondary transfer of DNA (for example, one person touches 

a phone, then another, and DNA from the first person is 

transferred via the phone to the second person). She did not 

deny it; rather, she testified that she had no reason to think it 
No. 13-1812 13 

had occurred in this case—no reason to think Vance’s DNA 

was on the latex gloves by reason of having been transferred 

to the gloves by someone or something innocently touched 

by Vance before the robbery. 

As for the testimony by the teller who had known Vance 

since childhood, Vance’s counsel argues that she could not 

have identified Vance as one of the robbers because he was 

masked. But a photograph taken by a surveillance camera at 

the bank (reproduced below) shows that Vance’s mask did 

not cover his entire face. That he could be identified from 

such a photograph, though partially masked, by a person 

who had known him for many years was entirely plausible. 

United States v. Williams, 698 F.3d 374, 378 (7th Cir. 2012). His 

girlfriend also testified that he was the robber in the surveillance photograph. 

So much for guilt; on to punishment. Vance challenges 

his sentence of life imprisonment on the ground that 18 

U.S.C. § 2113(e)—the statute on which the sentence was 

based—is a hopeless muddle. It provides, so far as relates to 

this case, that a person who in the course of committing a 

bank robbery in violation of federal law “kills any person, or 
14 No. 13-1812 

forces any person to accompany him without the consent of 

such person, shall be imprisoned not less than ten years, or if 

death results shall be punished by death or life imprisonment.” It’s irrelevant that Vance appears not to have intended to kill the teller in the second bank robbery. He shot 

him in a buttock, and the bullet hit the iliac artery, causing 

him to bleed rapidly to death. It is reasonably clear that the 

language we quoted from the statute dispenses with any requirement of proving intent to kill, and in this respect duplicates the general federal felony-murder statute, 18 U.S.C. § 

1111(a). See United States v. Jackson, 736 F.3d 953, 957–58 

(10th Cir. 2013), and cases cited there; United States v. Allen, 

247 F.3d 741, 782–83 (8th Cir. 2001), vacated on other 

grounds, 536 U.S. 953 (2002). 

But that’s all that’s clear from the statutory text; for, issues of criminal intent to one side, read literally the statute 

makes no sense unless the victim happens to be the Biblical 

Lazarus. For read literally it says that a person who kills another person shall be punished by death or life imprisonment only if death results. But death is always the consequence of being killed. Even Lazarus was dead for four days 

before (according to the Gospel of John) Jesus Christ restored 

him to life. John 11:17. 

It’s silly for the government to invoke the statute’s “plain 

language” and “plain text” and insist that therefore “the sole 

function of the court[] is to enforce it according to its terms,” 

or to say that “the ‘if death results’ language may be considered redundant to the phrase, ‘kills any person’” (emphasis 

added). The statute is a mess. Nevertheless it is apparent 

what the drafters of the statute and the Congress that enacted it and the President who signed it intended, or if asked 
No. 13-1812 15 

(for it is uncertain who ever read the provision, buried as it 

is in a 356-page statute, Pub. L. 103-322, 108 Stat. 1796 (Sept. 

13, 1994)), would have said they intended: if in the course of 

committing a bank robbery the robber abducts someone, the 

minimum punishment is ten years in prison, but if he kills 

someone the minimum is life in prison. United States v. Parks, 

700 F.3d 775, 778–79 (6th Cir. 2012); cf. United States v. 

Turner, 389 F.3d 111, 120–21 (4th Cir. 2004). We know this is 

what was intended because the confusing “if death results” 

passage was substituted for “punished by death if the verdict of the jury shall so direct,” Pub. L. 103-322, § 60003(a)(9), 

108 Stat. 1969 (Sept. 13, 1994), in more than a dozen provisions of the federal criminal code, in order to eliminate the 

possibility that a jury would impose a death sentence for a 

bank robbery in which no one died. See H.R. Rep. No. 103-

466, at pp. 12–15 (March 25, 1994). The change had nothing 

to do with abduction. 

What else could the muddled statute mean? Vance’s interpretation is that if, as in this case, the person killed in a 

bank robbery is not abducted, the minimum sentence is 10 

years; only if he is both abducted and killed is it life. It 

would make no sense, however, to allow so lenient a sentence when death occurs, yet make the fact of abduction jack 

up the minimum sentence to life. Notice how broadly what 

we’re calling “abduction” is defined: “forces any person to 

accompany him” (him being the robber). This could mean 

forcing a teller to lead the robber to or toward the vault 

(which in fact happened here, which makes us wonder why 

there is any question about the legality of the life sentence)—

hardly a circumstance that would warrant jacking up the 

minimum sentence from 10 years to life. 
16 No. 13-1812 

Vance’s counsel invokes the rule of lenity. That rule of 

statutory interpretation can be understood in various ways: 

as backing up the prohibition against retroactive criminal 

punishment by requiring that a criminal statute be at least 

minimally clear; as underscoring the fact that there are no 

common law federal crimes and therefore judges are not to 

create crimes by interpreting ambiguous criminal statutory 

language as imposing criminal liability; and, least plausibly, 

as providing “fair warning” of potential criminal liability 

(unrealistic because most criminals are not familiar with the 

text of criminal statutes). The statute in this case is not actually vague or ambiguous; the text is nonsensical, presenting 

the familiar example of a statute or other legal document 

that can’t mean what it says—that read literally is nonsense—yet the meaning of which is obvious; and in such a 

case the obvious meaning is the legal meaning. “No rule of 

construction necessitates our acceptance of an interpretation 

resulting in patently absurd consequences.” United States v. 

Brown, 333 U.S. 18, 27 (1948); see also United States v. Kirby, 

74 (7 Wall.) U.S. 482, 486–87 (1868). 

The defendant raises additional issues, but they are peripheral and resolving them in his favor would not alter the 

outcome. One further point, however, unmentioned by the 

parties, deserves attention. It concerns the imposition of conditions of supervised release to take effect, as all such conditions do, when the defendant is released from prison after 

serving his prison sentence. What can it mean to impose on 

the defendant’s post-release conduct restrictions that because he’s been sentenced to life in prison will not take effect 

until his death? Yet this peculiar feature of Vance’s sentence 

is not unique; conditions of supervised release are routinely 

imposed in life-sentence cases. See, e.g., United States v. 
No. 13-1812 17 

Cavender, 228 F.3d 792, 797 (7th Cir. 2000); United States v. 

Rodríguez-Berríos, 573 F.3d 55, 60 n. 1 (1st Cir. 2009). Because 

the practice is routine, we are disinclined to criticize the district judge. And we are aware that the guidelines provisions 

relating to supervised release do not make an exception for 

life sentences, though such an exception could, as a matter of 

common sense, be thought implicit. 

When we raised this matter with the government’s lawyer at the oral argument, she pointed out that the defendant 

received multiple sentences, only one of which was a sentence of life imprisonment. Were that sentence to be reversed, whether on appeal or in a post-conviction proceeding or by presidential pardon or commutation, the defendant 

would be serving a sentence for a fixed number of years and 

so the conditions of supervised release might someday take 

effect. Fair enough. Yet Vance’s sentence states that among 

the counts of conviction to which the conditions of supervised release apply is the felony-murder count for which the 

life sentence was imposed, which will be the only sentence 

Vance serves if his convictions of the other counts in the indictment are vacated. 

A life sentence might be dismissed or commuted and replaced by a term of years. But that is far from certain to happen. The judge imposed 14 non-mandatory conditions of supervised release on Vance, which might in the unusual circumstances of conditions imposed on a defendant sentenced 

for life be excessive. For future reference, we emphasize the 

importance of care in the supervised-release stage of sentencing, which sometimes gets short shrift from busy judges. 

See United States v. Siegel, 753 F.3d 705 (7th Cir. 2014); United 

States v. Bryant, 754 F.3d 443 (7th Cir. 2014). 
18 No. 13-1812 

A similar feature of the sentence was to make the term 

sentences run consecutive to the life sentence, although 

again it could be argued that this was done in case the life 

sentence should be commuted to a term of years, or vacated 

entirely. Obviously the judge did not mean that after dying 

in prison Vance is to begin serving those other sentences. 

As we said, Vance’s lawyer has made no issue of the conditions of supervised release imposed as part of the sentence, or for that matter the imposition of sentences to run 

consecutively to Vance’s life sentence. So we shall let the entire judgment stand. 

AFFIRMED.