Double Jeopardy and the Crime of Burglary

In the case of Robert Gorham versus the State of Florida, Mr. Gorham was convicted of two counts of burglary of a conveyance with an assault or battery.  His convictions were based on a single entry but involved two different victims.

Gorham appealed his convictions, and the appellate court ruled that:

1.  His two convictions for burglary was a double-jeopardy violation.

2.  It is the number of entries that triggers burglary charges, not the number of victims.

3.  Because Gorham entered the conveyance only once, he could be convicted of burglary only once.