State v. Sambath Pal, 893 N.W.2d 848

April 20, 2014: Pal's SUV struck a group of motorcyclists; two victims later died. Pal left the scene.
Evidence (vehicle debris, matching SUV, family/girlfriend statements) tied Pal to the crash; he was arrested April 24–25, 2014.
Pal was charged with two counts of hit-and-run resulting in death (one count per deceased motorcyclist), pleaded guilty to both, and received consecutive sentences (each: 10 years initial confinement + 10 years extended supervision).
Pal moved for postconviction relief arguing (1) multiplicity/double jeopardy (only one offense—flight) and (2) sentence was unduly harsh; both the circuit court and court of appeals rejected his claims.
The Wisconsin Supreme Court granted review and affirmed: it held the two counts were distinct (duties owed to each victim) and the sentence was within discretion and not unduly harsh.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether charging Pal with two counts under Wis. Stat. § 346.67(1) violated double jeopardy / multiplicity rules	Pal: flight was a single act; statute triggered once per accident so only one punishable offense	State: statute imposes duties to each person injured or killed; separate failures to perform duties to each victim support separate counts	Held: Offenses were not identical in fact; legislature authorized multiple punishments where multiple victims exist, so no multiplicity/DJ violation
Whether the sentence (two consecutive 20-year terms) was unduly harsh	Pal: sentence was excessive given circumstances and plea/remorse	State: sentence within statutory range; court considered gravity, defendant's conduct, lack of remorse, protection of public	Held: Sentence below statutory maximum; trial court properly weighed factors; sentence not unduly harsh or unconscionable

State v. Ziegler, 342 Wis. 2d 256 (2012) (articulates Wisconsin's two-pronged multiplicity test and standard of review)
State v. Davison, 263 Wis. 2d 145 (2003) (discusses double jeopardy and multiplicity principles)
State v. Patterson, 329 Wis. 2d 599 (2010) (presumption that legislature authorized multiple punishments when offenses differ in fact)
State v. Rabe, 96 Wis. 2d 48 (1980) (where crime is against persons, generally as many offenses as individuals affected)
State v. Hartnek, 146 Wis. 2d 188 (Ct. App. 1988) (upheld multiple counts for a single hit-and-run event with multiple victims)
State v. Richter, 189 Wis. 2d 105 (Ct. App. 1994) (proof must show failure to complete statutory duties as to each victim)
State v. Cummings, 357 Wis. 2d 1 (2014) (standard for reviewing whether a sentence is unduly harsh)
Blockburger v. United States, 284 U.S. 299 (1932) (classic elements/same‑offense test referenced in multiplicity analysis)
Ladner v. United States, 358 U.S. 169 (1958) (unit-of-prosecution approach when multiple victims are implicated)
Sanabria v. United States, 437 U.S. 54 (1978) (distinguishes unit-of-prosecution/unit charges from Blockburger contexts)