California, United States of America
The following excerpt is from People v. Finley, F076066 (Cal. App. 2018):
The court followed similar logic in People v. Felix (2001) 92 Cal.App.4th 905, where the court declined to apply section 654 to two convictions for criminal threats made to the same victim two hours apart. The court reasoned the defendant had time to reflect between the first and second threat, and that "multiple crimes are not one transaction where the defendant had a chance to reflect between offenses and each offense created a new risk of harm." (Id. at p. 915.)
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