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Name: People v. Coyle
Case #: C058218
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 10/09/2009

Three convictions for murder based on a single criminal act were improper. Coyle was charged with three counts of first-degree murder with gun enhancements: murder in the course of a robbery, murder in the course of a burglary, and murder, all against the same victim. He was convicted on all three counts, with special circumstances in the first two and an inherent finding of malice in the third, and sentenced to life without parole (LWOP) tripled under the Three Strikes law. The appellate court agreed with appellant’s contention that he could not be properly convicted on all three counts, because they all alleged the same crime, merely under alternative theories. However, it agreed with the People’s contention that the judgment could be consolidated to reflect a single conviction with all of the findings inherent in the three convictions returned at trial. Accordingly, the court reversed and vacated two of the three murder convictions, and modified the third conviction to reflect the robbery murder and burglary murder special circumstances, a finding of malice, and true findings as to all accompanying firearm enhancements. The court also accepted the prosecutor’s concession that a sentence of LWOP cannot be tripled under the Three Strikes law, and accordingly modified the sentence on the murder count to a single LWOP.