Can a defendant who commits a burglary as an incident and means of perpetrating another felony be punished separately for the crime?

Ordinarily, a defendant who commits burglary as an incident and means of perpetrating another felony may not be punished separately for the burglary. (People v. Centers (1999) 73 Cal.App.4th 84, 98 [citing cases].) There are exceptions, however. For example, violent crimes with multiple victims can be separately punished because when a crime of violence is committed with the intent to harm more than one person or in a way likely to harm several persons, greater culpability precludes application of section 654. (Id. at p. 99 [upholding sentences for both burglary and kidnapping when second occupant of dwelling was traumatized but not kidnapped].) Multiple punishments are also upheld when a defendant has multiple objectives, such as to steal and to inflict physical harm. (People v. Nelson (1989) 211 Cal.App.3d 634, 638-339 [affirming separate punishment for burglary and assaults].)

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