Running a Sentence Consecutively to an Anticipated Sentence

May the judge sentencing a conviction now order that it run consecutively to sentences the defendant might get in the future? The General Statutes don’t explicitly say. G.S. 15A-1354(a) notes two situations in which consecutive sentences may be imposed: when multiple sentences are entered at the same time, or when a new term of imprisonment is being imposed on a person who is already subject to an undischarged term of imprisonment. The law makes no mention of any authority for the judge sentencing a conviction now to preemptively determine how today’s sentence will relate to those imposed in the future. A recent North Carolina case briefly considered the question. In State v. Fleming, __ N.C. App. __ (June 7, 2016), the defendant was convicted of common law robbery, conspiracy to commit common law robbery, and some other charges. The judge ordered the sentences to run consecutively to one another, and also consecutively “to any other sentence he may get in the future.” Appellant Brief at 31. The defendant appealed. The court of appeals hinted that the latter remark may have been improper, but no record of it made its way into the trial court's written judgment. Because the written judgment controlled, the appellate court found no error. Had the judge’s comment been reflected in the written judgment, I think it probably would have been deemed erroneous. There is no clear statutory procedure for starting a sentence only to put it on hold later if another sentence is entered before the first one [...]