Does Section 654 bar a defendant from a range of criminal convictions based on separate intents?

"The defendant's intent and objective present factual questions for the trial court, and its findings will be upheld if supported by substantial evidence. [Citation.] 'We review the court's determination of [a defendant's] "separate intents" for sufficient evidence in a light most favorable to the judgment, and presume in support of the court's conclusion the existence of every fact the trier of fact could reasonably deduce from the evidence.'" (People v. Andra (2007) 156 Cal.App.4th 638, 640-641.) That the crimes were purportedly part of a single, overall schemeto fraudulently obtain goods or services by using the stolen propertydoes not mean section 654 bars punishment for all of the crimes.

Defendant's reliance on People v. Jaramillo (1976) 16 Cal.3d 752 and People v. Landis (1996) 51 Cal.App.4th 1247 is misplaced. Both cases involved circumstances where the defendant was convicted of burglary and of being in possession of stolen property. The stolen property at issue was the same property taken in the burglaries. Because the same property provided the basis for the convictions, section 654 barred multiple punishment. In contrast, in this case, the stolen property was the check and the credit card. The burglaries were committed by defendant's entry into commercial establishments with the intent to use the stolen property to obtain either

Page 15