What is the test for establishing a common plan and identity?

"To establish the existence of a common plan or scheme, 'the common features must indicate the existence of a plan rather than a series of similar spontaneous acts, but the plan thus revealed need not be distinctive or unusual.' " (People v. Avila (2006) 38 Cal.4th 491, 586.) The evidence in this case revealed a common plan even though the plan was not " 'distinctive or unusual.' "

In People v. Capistrano (2014) 59 Cal.4th 830, the court found the following evidence to be cross-admissible to prove common plan and identity. There, three home invasion robberies were found sufficiently similar to prove common plan and identity because in each "a victim's car was taken," the robberies occurred "within the same geographical area" over a one-month period, in two cases the victims "were initially approached in their garages as they returned home," the robbers "covered their faces with ski masks," and "asked similar questions of the victims." (Id. at p. 849.) We find no significant difference between the plan found to be sufficiently similar in Capistrano and the evidence in this case.