California, United States of America
The following excerpt is from People v. Berry, B254509 (Cal. App. 2015):
Generally, the trial court has broad discretion in determining whether a defendant had multiple criminal objectives independent of, and not merely incidental to, each other for purposes of section 654. Here the trial court made no express findings. While on appeal we will uphold the court's express or implied finding a defendant held multiple criminal objectives if it is supported by substantial evidence (see People v. Robinson (2010) 47 Cal.4th 1104, 1126), here the record does not support that finding.
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