Does section 654 of the California Criminal Code allow a defendant to be convicted of a single charge of street terrorism and a separate charge of attempted murder for a single drive-by shooting?

Section 654 does not include any language that permits the circumvention of the prohibition against multiple punishments because a defendant had multiple intents or intended multiple impacts in a single act scenario. The cases interpreting section 654 require a trial court to determine whether the series of acts amount to a course of conduct subject to a single intent, or multiple intents and objectives, only when a defendant engages in multiple acts. Herrera, supra, 70 Cal.App.4th 1456, appears to have extended the "intent and objective" test articulated in Neal v. State of California (1960) 55 Cal.2d 11, to impose separate punishments for the street terrorism offense and the underlying felony even if those offenses arise out of a single act. (Herrera, supra, 70 Cal.App.4th at p. 1468; Sanchez, supra, 179 Cal.App.4th at p. 1312 [Herrera treated defendant's two counts of attempted murder as a single drive-by shooting].)