Does Section 654 of the Criminal Code require a consecutive sentence for battery with serious bodily injury against a pimping victim?

The fact that the jury found both the battery and the pimping were committed with the intent to promote a gang (the pimping because it brings money into the gang, and the battery because it facilitates the pimping) does not mean the two crimes had entirely identical intents and objectives. "'[T]o accept . . . a broad, overriding intent and objective to preclude punishment for otherwise clearly separate offenses would violate [section 654's] purpose to insure that a defendant's punishment will be commensurate with his culpability.'" (People v. Jones (2001) 25 Cal.4th 98, 110, fn. 7; accord, People v. DeVaughn (2014) 227 Cal.App.4th 1092, 1116.) Because the two crimes involved separate intents (albeit with a shared "'broad, overriding intent and objective'"), the court did not err in imposing the consecutive sentence for battery with serious bodily injury.¹⁹

H. Cumulative Error Does Not Require Reversal