California, United States of America
The following excerpt is from People v. Scheer, 68 Cal.App.4th 1009, 80 Cal.Rptr.2d 676 (Cal. App. 1998):
Moreover, commission of the prior flight offense does not provide a motive, i.e., incentive, for appellant to commit the current crime. (Cf. People v. Arias (1996) 13 Cal.4th 92, 127-128, 51 Cal.Rptr.2d 770, 913 P.2d 980 [kidnapping and robbery of victim was motivated by defendant's need for money and transportation to escape apprehension for crimes committed 13 days earlier].)
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