California, United States of America
The following excerpt is from People v. Bland, 14 Cal.App.4th 1441, 18 Cal.Rptr.2d 339 (Cal. App. 1993):
Here, defendant argues that because the cocaine was found in two different units in two different locations in the house the jurors could have attached liability for possession of cocaine base for sale from different factual bases. Relying on the reasoning used by this court in People v. King (1991) 231 Cal.App.3d 493, 282 Cal.Rptr. 402, defendant argues that constructive possession was based on different acts of possession, reasonably distinguished by a separation in space, i.e., the bedroom and the [14 Cal.App.4th 959] [24 Cal.App.4th 1240] [14 Cal.App.4th 830] kitchen, and thus "[c]ertain jurors might have been convinced defendant possessed the cocaine base found in the kitchen while others were convinced he possessed the cocaine base found in the bedroom without all jurors at a minimum believing he possessed any one unit of cocaine base."
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