Does section 654 of the California Criminal Code prohibit a trial court from imposing multiple punishments for the same act?

California, United States of America


The following excerpt is from People v. Townsend, B258676 (Cal. App. 2016):

Section 654 prohibits a trial court from imposing multiple punishments for the same act even though the same act violates multiple criminal statutes. ( 654, subd. (a).) "The purpose of the protection against multiple punishment is to [e]nsure that the defendant's punishment will be commensurate with his criminal liability." (Neal v. State (1960) 55 Cal.2d 11, 20.)

When a defendant's actions are a course of criminal conduct, to determine whether section 654 precludes multiple punishments, the test is to look at the defendant's criminal objective and intent. (See People v. Beamon (1973) 8 Cal.3d 625, 638-639.) When the defendant has multiple criminal objectives independent of each other, the course of conduct is divisible into separate acts such that the court may punish the defendant for each violation committed in pursuit of an independent criminal objective. (See id. at p. 639.)

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