In what circumstances will the trial court combine charges of first-degree murder and escape from custody?

California, United States of America


The following excerpt is from People v. Gonzalez, A145857 (Cal. App. 2017):

In People v. Valdez (2004) 32 Cal.4th 73 (Valdez), the trial court jointly tried Valdez for first-degree murder and an escape from custody charge. (Id. at p. 119.) On appeal, the court held that although the two offenses occurred almost two years apart, they were connected in their commission because the escape occurred as Valdez was

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