1. United States of America
2. New Caledonia
3. ); see also Nancy Ehrenreich, Attempt, Merger and Transferred Intent, 82 BROOK;Anne Bowen Poulin;Double Jeopardy Protection from Successive Prosecution: A Proposed Approach, 92 GEO. L. J. 1183,2004
4. stating that the test has been "increasingly criticized as not coping satisfactorily with the problem it was designed to solve"). The test has also been criticized as "difficult to administer in practice;Marc E Nolan;Comment, Diverging Views on the Merger of Criminal Offenses: Colorado Has Veered Off Course, 66 U. COLO. L. REV,1995