The 2nd, 9th and 8th circuits, for instance, have all found this requirement squares with the requirements of constitutional due process. United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998); Sanchez v. United States, 50 F.3d 1448, 1453 (9th Cir. 1995); White v. United States, 858 F.2d 416, 422 (8th Cir. 1988)). States that find the same include Colorado (In re Attorney C, 47 P.3d 1167 (Colo. 2002)) and Nevada (State v. Huebler, 275 P.3d 91 (Nev. 2012).