Can a single act or course of conduct constitute torture?

Torture can be committed either by a single act or by a course of conduct. (People v. Hamlin (2009) 170 Cal.App.4th 1412, 1429, 89 Cal.Rptr.3d 402.) Where torture is tried as a course of conduct crime, it is not necessary that any single act in the course of conduct results in great bodily injury. Rather, if the requisite intent exists and the cumulative result of the course of conduct is great bodily injury, the crime of torture has been committed. (Ibid . ) Here, the prosecutor argued that torture is not necessarily "something that happens with one punch or ... one strangulation, or ... one rape, or one sodomy or one of something." She argued that in this case, the torture consisted of the acts shown on the videos, as well as "how the

[9 Cal.App.5th 1044]