How Many Charges Can One Charging Document Contain?

How many charges can be placed on a single charging document, such as a citation, an arrest warrant, or an indictment? Old hands use the rule of thumb, no more than two charges per citation, no more than three charges in any other pleading. But where does that rule come from? And is it even correct? No constitutional limit. There is no constitutional limit to the number of charges than can be brought in a single charging document. So long as each charge is supported by probable cause and is properly alleged, whether the charges are brought in a single document or broken up into multiple documents does not matter. Indeed, massive multi-count charging documents are common in some jurisdictions. See, e.g., United States v. Beech-Nut Nutrition Corp., 659 F. Supp. 1487 (E.D.N.Y. 1987) (noting that “the Government filed a 470 count indictment against . . . eight defendants”); Vincent v. Com., 281 S.W.3d 785 (Ky. 2009) (noting that defendant was charged with multiple sex crimes in a 294-count indictment); Friedman v. Rehal, 618 F.3d 142 (2d Cir. 2010) (stating that “petitioner was charged [in the courts of New York] with two hundred and forty-three counts of sexual abuse in three separate indictments”); People v. Kimyagarova, 790 N.Y.S.2d 811 (N.Y. Supr. Ct. 2004) (describing a “one hundred count indictment against twenty defendants alleging insurance fraud” and other offenses); State v. G.M.W., Jr., 916 So.2d 460 (La. Ct. App. 2005) (stating that each of two indictments “charged Defendant with one hundred and [...]