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In Affronti v. United States, the Supreme Court ruled that a district court could not issue multiple probation orders for separate offenses arising from the same criminal proceeding. The case involved petitioner Frank Affronti who was convicted of four counts of mail fraud and one count of conspiracy to commit mail fraud in 1950. He was sentenced to five years' imprisonment on each count, with sentences running concurrently except for the last year of the conspiracy sentence which was suspended and he was placed on probation following his release from prison. In 1953, while still serving his prison term but after having begun his period of probation as well, he violated terms of his parole by committing another crime. As a result, an arrest warrant issued charging him with violation of probation conditions imposed under both sentences. Affronti argued that since he had already started serving out his first sentence's probationary period when arrested again in 1953; therefore it would be double jeopardy if additional punishment were added due to violating terms set forth during this time frame too (which included second offense). However upon review at Supreme Court level they disagreed stating instead once someone has been put onto such restrictions then all future actions can potentially impact their status regardless whether or not these occurred prior versus post initial sentencing date.
In the dissenting opinion for Affronti v. United States, Justice Frankfurter argued that the majority's interpretation of 18 U.S.C. § 4202 was incorrect and too restrictive. He contended that the statute should be read to allow a parole board to consider an inmate for parole at any time after he has served one-third of his sentence, rather than only once he has served one-third of all sentences imposed upon him consecutively. The justice believed this reading would better align with Congress' intent when it enacted § 4202 and would avoid unnecessarily prolonging imprisonment in cases where consecutive sentences are imposed. Furthermore, Justice Frankfurter pointed out potential practical difficulties arising from the majority's interpretation such as administrative burdens on prison officials who must calculate cumulative sentences before considering inmates for parole.