People v. First Meridian Planning Corp

In People v. First Meridian Planning Corp. (86 N.Y.2d 608 [1995]), the Court of Appeals rejected a claim that a count in an indictment charging scheme to defraud in the first degree was duplicitous because it alleged more than one offense (see, CPL 200.30 [1]). The Court wrote that "where ... a crime by its nature as defined in the Penal Law may be committed either by one act or by multiple acts and can be characterized as a continuing offense over time, the indictment may charge the continuing offense in a single count." The Court did not hold, however, that such a crime must be charged in a single count.