In People v. Bailey (1961) 55 Cal.2d 514, the Supreme Court held that for purposes of determining whether a defendant is guilty of grand theft, the value of stolen property from separate incidents of thefts may be aggregated if "the evidence established that there was only one intention, one general impulse, and one plan." (Bailey, supra, 55 Cal.2d at p. 519.) In In re Arthur V. (2008) 166 Cal.App.4th 61, the appellate court applied Bailey's reasoning to hold that damages from separate incidents of vandalism--each causing damages of less than $400--could be aggregated, "unless 'the evidence shows that the offenses are separate and distinct and were not committed pursuant to one intention, one general impulse, and one plan.'" (Arthur V., supra, 166 Cal.App.4th at p. 69, quoting Bailey, supra, 55 Cal.2d at p. 519.) Arthur V. involved an incident in which the defendant and his friends smashed the windshield of the victim's car, causing $150 of damages, and then kicked the victim, causing him to drop his cell phone, resulting in an additional $350 of damages. (Arthur V., at p. 65.) The Arthur V. court held that the damages to the car windshield and the cell phone could be aggregated under the doctrine established in Bailey. (Arthur V., at pp. 68-69.) In applying Bailey's holding regarding grand theft to charges of vandalism, the Arthur V. court reasoned that the difference between misdemeanor vandalism and felony vandalism (which is based upon the amount of damages) is analogous to the difference between petty theft and grand theft (also based upon a damages amount). (Arthur V., at p. 68.) The Arthur V. court distinguished In re David D. (1997) 52 Cal.App.4th 304, which had questioned but not decided whether the Bailey doctrine applied to vandalism cases. (Arthur V., supra, 166 Cal.App.4th at pp. 66-67.) In David D., the defendant was charged with tagging or spray painting multiple residences and businesses throughout the city during the course of an evening. (David D., at pp. 306, 310.) After noting that Bailey had been limited "not only to the crime of theft, but generally to thefts involving a single victim," the court went on to state that it "did not intend to imply ... that the Bailey doctrine can never be appropriate to a theft or thefts from multiple victims." (David D., at p. 309 & fn. 3.) In any event, the court concluded that application of the Bailey doctrine to the facts before it was inappropriate, as "each tagging incident clearly represented a separate offense affecting a different victim." (David D., at p. 311.) The Arthur V. court expressly rejected any suggestion that damages from crimes against multiple victims could never be aggregated under the Bailey doctrine. Although Arthur V. involved the property of a single victim, the court stated that "the existence of multiple victims will not necessarily preclude aggregation. For example, an offense consisting of the spray painting of one's name across property owned by multiple persons would clearly be properly aggregated into a single count, despite the presence of multiple victims." (Arthur V., supra, 166 Cal.App.4th at pp. 68-69, fn. 4.)