People v. Lawrence

In People v. Lawrence (2000) 24 Cal.4th 219, the court reversed the Court of Appeal and concluded that Lawrence's current offenses did not occur on the same occasion or arise from the same set of operative facts despite the fact that he was still in flight after shoplifting a bottle of brandy when he decided to trespass into a backyard and then assault the occupants with the bottle as he was chased out of the yard. (Id. at p. 234.) As the court explained: "The first crime involved an act of theft directed at one group of victims, the second involved assaultive conduct directed at an unrelated pair of victims. The two criminal episodes were separated spatially by at least one to three city blocks, and temporally by two to three or more minutes (from the time defendant stole the brandy from the market until the point he committed the aggravated assault upon LaVastida after having fled from the first crime scene, trespassed into the Rojas/LaVastida backyard, and fled again, chased by Rojas out of the yard and down a long driveway to the street, where he hit LaVastida with the bottle before being subdued)." (Ibid.)