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Name: People v. Meeks
Case #: C036854
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 04/13/2004
Subsequent History: Depublished 7/21/04

Appellant was sentenced to state prison for 25 years to life for two counts of failure to register after changing his address, with three prior “strike” convictions. On appeal, he contended that the trial court erred in denying his challenges to multiple counts for the single continuing offense of failure to register. The appellate court here held that separate convictions for failure to register upon a change of address and to register annually on his birthday were lawful. Under section 290, a failure to register when one moves is one continuing offense; a failure to register on one’s birthday is a separate continuing offense. Appellant also argued that the second count should have been stayed pursuant to section 654. The court rejected this argument for the same reasons: each count constituted an offense unrelated to the other. Finally, the court rejected appellant’s contention that a sentence of 25 years to life for failing to register constitutes cruel and/or unusual punishment under the constitution. J. Sims dissented, holding that the sentence constituted cruel or unusual punishment. The sentence imposed was so disproportionate to the crime that it shocks the conscience and offends fundamental notions of human dignity.