People v. Hurt, 317 Cal.Rptr.3d 421

Sarah Rachel Hurt was convicted of various weapon and drug offenses occurring during three separate incidents in 2021.
Some offenses were committed while she was out on bail for earlier offenses, all originally charged in one case.
Evidence from the search of a hotel room and other uncharged acts were introduced at trial to show intent and knowledge.
The trial court consolidated all offenses for one trial, admitted evidence of the hotel search, and imposed two on-bail enhancements.
On appeal, Hurt challenged the consolidation, the evidence’s admissibility, and the multiple on-bail enhancements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Consolidation of offenses for trial	Offenses were connected by common intent and class	Cases not connected, evidence not cross-admissible	Consolidation was proper
Admission of uncharged acts evidence	Relevant to prove intent/knowledge; not unduly prejudicial	Evidence was propensity-based and prejudicial	Admission was proper
Cumulative error	No individual errors occurred	Combined errors violated due process	No cumulative error, as no individual error
Multiple on-bail enhancements	Enhancement allowed per each primary offense	Only one enhancement per case permitted	Only one enhancement allowed; second stricken

People v. Westerfield, 6 Cal.5th 632 (joinder of offenses requires connection by substantial common element)
People v. Ewoldt, 7 Cal.4th 380 (admissibility of prior acts under Evid. Code § 1101(b))
People v. Tassell, 36 Cal.3d 77 (distinction between enhancement types in sentencing)
People v. Warinner, 200 Cal.App.3d 1352 (on-bail enhancement applies per case, not per offense)
People v. Mackabee, 214 Cal.App.3d 1250 (limit of one on-bail enhancement per case)