People v. Corrigan
Annotate this CaseCorrigan pleaded no contest to four charges, including one count of unlawfully causing a fire that caused an inhabited structure or inhabited property to burn under Penal Code section 452(b) and one count of unlawfully causing a fire of a structure or forest land under subdivision (c) of that statute. The trial court sentenced him to seven years in prison, including a one-year term for the first section 452 conviction and a stayed two-year term for the other. On appeal, he argued that under section 954 he could be convicted of either of the counts, but not both, because they were based on a single fire. The court of appeal affirmed. Although the convictions were based on the same act or course of conduct, both convictions were nonetheless authorized under section 954. Subdivisions (b) and (c) define different offenses instead of merely describing different ways of committing the same offense.
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