California, United States of America
The following excerpt is from People v. Harrison, 256 Cal.Rptr. 401, 48 Cal.3d 321, 768 P.2d 1078 (Cal. 1989):
We agree. No purpose is to be served under section 654 by distinguishing between defendants based solely upon the type or sequence of their offenses. Such an analysis would dispense punishment on the basis of the sexual taste or imagination of the perpetrator, and would not address the concerns raised in Perez, supra, 23 Cal.3d 545, 153 Cal.Rptr. 40, 591 P.2d 63. To adopt such an approach would mean that "once a [defendant] has committed one particular sexual crime against a victim he may thereafter with impunity repeat his offense," so long as he does not direct attention to another place on the victim's body, or significantly delay in between each offense. (People v. Reeder, supra, 152 Cal.App.3d at p. 917, 200 Cal.Rptr. 479.) However, it is defendant's intent to commit a number of separate base criminal acts upon his victim, and not the precise code [48 Cal.3d 338] section under which he is thereafter convicted, which renders section 654 inapplicable.
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