State v. Kelly

In State v. Kelly, 190 Ariz. 532,6, 950 P.2d 1153, 1155 (1997), the Arizona Supreme Court identified five factors to be considered when determining whether offenses were committed on the same occasion: "1) time; 2) place; 3) number of victims; 4) whether the crimes were continuous and uninterrupted; 5) whether they were directed to the accomplishment of a single criminal objective." The Court in Kelly was rejecting an argument that the single criminal objective factor constituted a standalone test. 190 Ariz. 532,9, 950 P.2d at 1156.