State v. Crawford
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The Supreme Court reversed Defendant's conviction and sentence for ongoing criminal conduct and Defendant's conviction for robbery in the first degree, holding that Defendant's conduct did not satisfy the requirements for ongoing criminal conduct.
Defendant was indicted for his participation in a three-week crime spree that involved using a torch to cut into an ATM, robbing a bank, and using the proceeds to buy and subsequently sell marijuana. Defendant was convicted of first-degree robbery and ongoing criminal conduct and sentenced to twenty-five years on each. The Supreme Court vacated the convictions at issue, holding (1) the State presented insufficient evidence to establish the continuing basis element of the ongoing criminal conduct charge; and (2) Defendant's conviction for robbery in the first degree is vacated and the case remanded for entry of judgment and sentencing for robbery in the second degree.
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