Aug. 1, 2022 – People v. Henson (Supreme Ct., S252702)

Defendant was held to answer on two felony complaints within a 15-day period, and the prosecution filed a single information charging the offenses from both complaints, thereby effectively consolidating the two cases without the filing of a motion to consolidate. In a 4-3 decision, the Supreme Court upholds this practice as a proper instance of joinder under PC 954. Justice Kruger, joined by Justices Groban and Liu, writes in dissent that, absent a consolidation order, an information “may charge only those offenses contained in a single commitment order or shown by the evidence at a single preliminary hearing.”