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P. v. Ohlinger CA4/1
Defendant William Dexter Ohlinger was sentenced to 22 years in prison based on a 20-count amended information that included multiple enhancements for crimes he committed between April and September 2019. These crimes were committed by Ohlinger while a member of the White Power Gangsters (WPG), and included robbery, burglary, possession of a firearm and live ammunition, transportation of methamphetamine for sale, false impersonation, felony evasion, and participation in a criminal street gang. By mid-2019, WPG had committed about 80 robberies and burglaries of marijuana grow houses, with the proceeds benefitting WPG and the Aryan Brotherhood prison gang. All of the crimes in this case were investigated by the San Bernardino County Sheriff ’s Department.
On appeal, Ohlinger contends: (1) the trial court erred in failing to instruct the jury sua sponte on unanimity for second degree robbery (count 18);

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