In Erickson v. State, 950 P.2d 580, 587 (Alaska App. 1997), Brian Erickson was convicted of four counts of second-degree sexual abuse of a minor. The four counts involved one victim, but four different types of sexual penetration that occurred as part of a single incident. Erickson argued that the court should reverse the holding in Yearty that a defendant who perpetrates distinct types of sexual penetration during a single assaultive episode can be convicted separately for each type of sexual penetration. Erickson also argued that an appellate court is not permitted to create double jeopardy rules that will govern all future cases that present the same double jeopardy issue. In Erickson's case, the jury found that he engaged in four distinct types of sexual penetration. When "several distinct types of sexual penetration occur in the course of a single incident, the offense prohibited by the statute has been violated several times over." The court therefore held that Erickson was properly convicted of four counts of second-degree sexual abuse of a minor.