Does section 654 of the California Criminal Code prohibit multiple punishments for a single act or indivisible course of conduct?

California, United States of America


The following excerpt is from People v. Patterson, B277189 (Cal. App. 2017):

"Section 654 precludes multiple punishments for a single act or indivisible course of conduct." (People v. Hester (2000) 22 Cal.4th 290, 294.) In determining whether multiple punishments run afoul of section 654, we look to a defendant's intent and objective. "[I]f all of the offenses were merely incidental to, or were the means of accomplishing or facilitating one objective, defendant may be found to have harbored a single intent and therefore may be punished only once." (People v. Harrison (1989) 48 Cal.3d 321, 335.) Robbing the victims while they were captive in back room was an objective independent of stealing from the store safe. Multiple punishments were not prohibited.

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The judgments are affirmed.

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