California, United States of America
The following excerpt is from People v. Quiroz, F076537 (Cal. App. 2019):
Multiple convictions may not be based upon necessarily included offenses. (People v. Flores (2005) 129 Cal.App.4th 174, 184 (Flores).) Where an offense cannot be committed without necessarily committing another, the latter is a necessarily included offense. (Ibid.)
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