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Double Jeopardy – Multiplicity: Sexual Assaults, Single Incident

State v. David J. Cleveland, 2000 WI App 142, 237 Wis. 2d 558, 614 N.W.2d 543
For Cleveland: Suzanne L. Hagopian, SPD, Madison Appellate

Issue: Whether multiple sexual assault counts arising during a single incident violated double jeopardy.

Holding: Though the offenses weren’t separated in time, each required separate volitional acts and were therefore significantly different in nature for double jeopardy purposes. ¶¶24-26.

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