California, United States of America
The following excerpt is from People v. Jenks, C089797 (Cal. App. 2020):
In Britt, the court ruled that section 654 precluded multiple punishment for failures to notify authorities in a county defendant moved to and authorities in the county defendant moved from, two separate sex-offender registration crimes. (People v. Britt, supra, 32 Cal.4th at pp. 949, 951-954.) The court disagreed with the decision on review, which concluded that defendant "had two separate objectives: '(1) to mislead law enforcement and the residents of one community to believe that the sex offender remains there; and (2) to conceal from law enforcement and the residents of another community the fact that the sex offender is now residing in that community.' " (Id. at p. 953.) The court explained, "Here the objective -- avoiding police surveillance -- was achieved just once, but only by the combination of both reporting violations." (Ibid.) "[F]inding separate objectives here -- to mislead or conceal information from the law enforcement agency in each county -- parses the objectives too finely." (Ibid.)
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