California, United States of America
The following excerpt is from People v. Canady, F068093 (Cal. App. 2015):
Canady acknowledges that his position is weakened by the holding in People v. Washington (1996) 50 Cal.App.4th 568 (Washington), which concludes that because the crime of burglary is complete upon entry with the requisite intent, each unlawful entry committed with the required mental state supports a separate conviction. (Id. at pp. 575-579 [defendant found guilty of two counts of burglary based on unlawful entries into the same apartment within a span of approximately 2 hours and 15 minutes].) He tries to
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distinguish Washington on grounds that the present case involved only one successful "entry" that occurred within moments of the conduct upon which the attempted burglary conviction was based. The argument is unconvincing, as Washington merely illustrates the general rule that "a defendant may be convicted of multiple crimes - even if the crimes are part of the same impulse, intention or plan - as long as each conviction reflects a completed criminal act." (People v. Kirvin (2014) 231 Cal.App.4th 1507, 1518 [citing numerous examples of the rule's applicability to "crimes that do not monetize and aggregate harm or damage."].)
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