California, United States of America
The following excerpt is from People v. Maddox, B234514 (Cal. App. 2014):
"California intermediate appellate courts are presently divided on whether the trial court has a duty to instruct the jury on single versus multiple conspiracies. [Citations.]" (People v. Meneses, supra, 165 Cal.App.4th at p. 1668.) Most decisions, including the most recent cases, have held the trial court has a duty to instruct the jury to decide whether there was a single or multiple conspiracies where there is evidence to support alternative findings. (See, e.g., id. at p. 1671; People v. Jasso (2006) 142 Cal.App.4th 1213, 1220.)
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