AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The case involves the Defendant, Juan Navarro, who was convicted of four counts of second-degree criminal sexual contact of a minor (CSCM) and one count of false imprisonment. The charges arose from incidents where the Defendant sexually assaulted a minor, referred to as Victim, on four different days. The appeal focuses on events that occurred on the second day of abuse, during which the Victim testified that the Defendant sexually assaulted her twice in two different locations within his home: once in the living room and once in a bedroom, where he also physically restrained her (para 2).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that the convictions for CSCM and false imprisonment violate double jeopardy because they were based on a single course of conduct, with the CSCM subsuming the elements of false imprisonment. The Defendant contended that the conduct was unitary and focused on the events in the bedroom to establish a double jeopardy issue (paras 3-4).
• Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

• Whether the Defendant's convictions for CSCM and false imprisonment violate double jeopardy principles due to arising from a single course of conduct.

Disposition

• The Court of Appeals affirmed the district court's convictions of the Defendant for CSCM and false imprisonment, rejecting the double jeopardy claim (para 9).

Reasons

• The Court, comprising Judges Katherine A. Wray, J. Miles Hanisee, and Megan P. Duffy, concluded that the Defendant's conduct was not unitary, thus not violating double jeopardy principles. The Court determined that the events in the living room and the bedroom were sufficiently distinct in time and space to support separate convictions for CSCM and false imprisonment. The Court declined to extend the "Foster presumption" to presume the jury convicted based on unitary conduct, noting the jury instructions did not limit the evidence to specific facts, allowing consideration of all Defendant's actions on the second day. The Court found an independent factual basis for each charged act based on the separation of events by time and space, and the distinct nature of the acts committed in each location (paras 3-8).