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In this situation, courts will examine “whether the offenses (1) occurred at substantially the same time and place and (2) arose from ‘a continuing and uninterrupted course of conduct, manifesting an indivisible state of mind or coincident errors of judgment.’” Bauer, d at 478 ().

(listing cases); -26 (Minn. 1980) (same).

The purpose of avoiding apprehension can unify multiple offenses if a subsequent offense was “substantially contemporaneously committed” “in order to avoid apprehension for the first offense.”

See, -14 (Minn. 1994) (concluding that defendant’s attempt to take the gun of an officer who kicked him down the stairs in order to “do” the officer was substantially contemporan eous with his aggravated robbery of the officer); State v. Gibson , (holding that criminal-vehicular-operation and leaving-the-scene-of-an-accident offenses were substantially contemporaneous where the defendant left the sce ne on foot “immediately after” the accident).

See, e.g., State v. Gibson , -98 (Minn. 1991) (vacating sentence for l eaving the scene of an accident where defendant immediately left the scene in order to avoid apprehension for criminal vehicular operation); (holding that escape from 19 custody sentence should be vacated where defen

Whether multiple crimes, at least one of which is nonintentional, 4 are part of the same behavioral incident depends on whether the offenses arise “out of a continuing and uninterrupted course of conduc t, manifesting an indivisible state of mind or coincident errors [in] judgment.” State v. Gibson , (M inn.

(“In a series of decisions —the avoidance-of-apprehension cases—we have held that multiple sentences may not be used for two offenses if the defendant, substantially contemporaneously committed the second offense in order to avoid apprehension for the first offense.”); see also State v. Boley, 29

When one offense includes an intent element and the other does not, the proper inquiry is whether the offenses “[arose] out of a continuing and uninterrupted course of conduct, manifesting an indivisible state of mind or coincident errors of judgment.” d 496, 497 (Minn. 1991) (quotation omitted).

Accordingly, because one of Whitaker’s offenses was not intentional, the proper test is whether the offenses “(1) occurred at substantially the same time and place and (2) arose from ‘a continuing and uninterrupted course of conduct, manifesting an indivisible state of mind or coincident errors of judgment.’” (), aff’d

rimes here does not contain an intentional component, the proper test is w h e t h e r t h e o f f e n s e s “(1) occurred at substantially the same time and place and (2) arose from ‘a continuing and uninterrupted course of conduct, manifesting an indivisible sta te of mind or coincident errors of judgment.’” (), aff’d

12 When one of t he crimes does not contain an intentional component, the proper test is whether the offenses “(1) occurred at substantially the same time and place and (2) arose from ‘a continuing and uninterrupted course of conduct, manifesting an indivisible state of mind or coincident errors of judgment.’” State v. Bauer , (), aff’d, d 825 (Minn. 2011).

“[M]ultiple sentences may not be used for two offenses if the defendant, substantially contemporaneously committed the second offense in order to avoid apprehension for the first offense.”

To determine whether offenses stem from a single course of conduct, we should “analyze all the facts and determine whether the offenses arose out of a continuing and uninterrupted course of conduct, manifesting an indivisible state of mind or coincident errors of judgment.” (quotation 11 omitted).

(explaining that when a defendant commits a substantially contemporaneous second offense in order to avoid apprehension for the first offense, both offenses are part of the same behavioral incident).

applies if “the offenses include both intentional and nonintentional crimes”; in that situation, “the proper inquiry is whether the offenses (1) occurred at substantially the same time and place and (2) arose from ‘a continuing and uninterrupted course of conduct, manifesting an indivisible state of mind or coincident errors of judgment.’” Bauer I, d at 478 ().

When the offenses include both intentional and nonintentional crimes, however, the proper inquiry is whether the offenses (1) occurred at substantially the same time and place and (2) arose from “a continuing and uninterrupted course of conduct, manifesting an indivisible state of mind or coincident errors of judgment.” (alteration in original) (quotation omitted).

There is insufficient evidence in the record to establish that appellant’s two offenses “arose out of a continuing and uninterrupted course of conduct, manifesting an indivisible state of mind or coincident errors of judgment.” (citation omitted).

When the offenses include both intentional and unintentional crimes, it must be determined whether the offenses “[arose] out of a continuing and uninterrupted course of conduct, manifesting an indivisible state of mind or coincident errors of judgment.” (citations omitted).

In determining whether two or more intentional crimes constituted one course of conduct, the court must consider the time and place of the crimes, and whether the “conduct involved was motivated by an effort to obtain but one criminal objective.”

In a series of decisions, this court has held that “multiple sentences may not be used for two offenses if the defendant, substantially contemporaneously committed the second offense in order to avoid apprehension for the first offense.” (citations omitted).