California, United States of America
The following excerpt is from People v. Wiley, B288508 (Cal. App. 2019):
Section 654 does not apply to crimes of violence against multiple victims. (People v. Oates (2004) 32 Cal.4th 1048, 1063 (Oates).) Section 654 aims to match punishment with culpability. A defendant who chooses a means of murder that places a group in danger is properly subject to greater punishment than a defendant who chooses a means that harms only a single person. (Ibid. ["For example, a defendant who chooses a means of murder that places a planeload of passengers in danger . . . is properly subject to greater punishment than a defendant who chooses a means that harms only a single person."].)
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