Can a defendant be convicted of leaving the scene of a single collision where there was no dispute that there was only one accident?

California, United States of America


The following excerpt is from People v. Campbell, 12 Cal.App.5th 666, 219 Cal.Rptr.3d 164 (Cal. App. 2017):

This case is unlike People v. Calles (2012) 209 Cal.App.4th 1200, 1209, 147 Cal.Rptr.3d 673, in which there could be only one conviction for leaving the scene of a single collision with multiple victims. The parties agreed there was only one accident: the defendant hit a single group of pedestrians who were walking together on the sidewalk. (Ibid . )

This case is also unlike People v. Newton (2007) 155 Cal.App.4th 1000, 66 Cal.Rptr.3d 422, in which one act caused a chain reaction collision. There, the defendant collided with a car, pushing that car into a third car. (Id . at p. 1002, 66 Cal.Rptr.3d 422.) There could be only one conviction for leaving the scene, even though four people were injured. Again, there was no dispute that there was a single accident for purposes of Vehicle Code section 20001, subdivision (a). (Ibid . ) The issue was whether having multiple victims would support multiple counts.

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