California, United States of America
The following excerpt is from People v. Evers, 10 Cal.App.4th 588, 12 Cal.Rptr.2d 637 (Cal. App. 1992):
10 While the "temporal proximity" of multiple crimes is not determinative of the applicability of section 654 (see People v. Ordonez (1991) 226 Cal.App.3d 1207, 1239, 277 Cal.Rptr. 382), it is a relevant consideration in the analysis. Evers has not cited, nor has our research disclosed, any case in which section 654 was held to apply to crimes committed with such a substantial time interval.
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