California Penal Code Section 136.1 - Witness Dissuasion

In People v. Salvato (1991) 234 Cal.App.3d 872, the court held that the crime defined by section 136.1 (dissuasion of a witness) set forth a course of conduct crime because the statute "focuses on an unlawful goal or effect ... rather than on any particular action taken to produce that end. ... The gravamen of the offense is the cumulative outcome of any number of acts, any one of which alone might not be criminal. Thus it falls within the continuous conduct exception ... ." (People v. Salvato, supra, 234 Cal.App.3d at p. 883.)