California, United States of America
The following excerpt is from People v. Heredia, D058535, Super. Ct. No. SCD220500 (Cal. App. 2012):
However, " 'the limitations of section 654 do not apply to crimes of violence against multiple victims.' " (People v. Oates, supra, 32 Cal.4th at p. 1063.) Even if the defendant has the same objective when committing a crime of violence against multiple victims, multiple punishment is warranted because a defendant who commits an act of violence " 'by a means likely to cause harm to several persons is more culpable than a defendant who harms only one person.' " (Ibid.)
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