discussed Cited "but see" New Jersey Education Association v. Fred G. Burke But cf. Ingraham v. Wright, 430 U.S. 651 , 97 S.Ct. 140 , 51 L.Ed.2d 711 (1977) (availability of state criminal and tort sanctions held to satisfy "due process" required for corporal punishment in schools) We have recently surveyed the plethora of decisions rejecting an exhaustion requirement for § 1983.

discussed Cited "but see" New Jersey Education Ass'n v. Burke But cf. Ingraham v. Wright, 430 U.S. 651 , 97 S.Ct. 140 , 51 L.Ed.2d 711 (1977) (availability of state criminal and tort sanctions held to satisfy “due process” required for corporal punishment in schools).

discussed Cited "see, e.g." Commonwealth v. Lundberg The Fourth Circuit, in response to this argument, noted: “It is doubtful that Rule 1406(a) was intended to apply where the two sentences in question have been imposed by different sovereigns. ‘Where different courts have sentenced [a person] for different offenses to be served at separate and distinct institutions,’ Pennsylvania courts presume ‘that the sentences are to run consecutively,’ and Rule 1406(a) does not apply.” Id. at 362 , n. 6 (citing Pfeiffer, supra); see also Gomori v. Arnold, 533 F.2d 871, 875 (3d Cir.1976), cert. denied, 429 U.S. 851 , 97 S.Ct. 140 , 50 L.Ed.2d 12…

discussed Cited "see, e.g." Lewis Thomas v. Patrick Whalen (2×) Commonwealth v. Pfeiffer, 396 Pa.Super. 641, 646 , 579 A.2d 897, 900 (1990); see also Gomori v. Arnold, 533 F.2d 871, 875 (3d Cir.) (holding that the "rule of presumptive concurrency of sentences, in the absence of a specific directive that sentences be served consecutively, does not apply where one sentence is imposed by a federal court and the other by a state court”), cert. denied, 429 U.S. 851 , 97 S.Ct. 140 , 50 L.Ed.2d 125 (1976).