What is the multiple victim exception to the crime of resisting arrest?

entertains but a single principal objective during an indivisible course of conduct, he may be convicted and punished for each crime of violence committed against a different victim.' [Citation.] The 'multiple victim' exception, like the other situations in which multiple punishment is permitted, is based on the greater culpability that attends commission of an act or acts of violence that may or do cause harm to more than one person." (People v. Deegan (2016) 247 Cal.App.4th 532, 542.)

People v. Martin (2005) 133 Cal.App.4th 776 involved the application of the multiple-victim exception to the crime of resisting an officer. In Martin, four officers arrived at the scene after the defendant's wife called the police following a domestic violence incident. The defendant was initially cooperative as the officers placed him under arrest and began escorting him to a patrol car, but he then attempted to escape, injuring one of the officers. The other officers knocked him to the ground and attempted to control him, while he resisted and kicked them. The defendant was convicted of both resisting arrest and battery on a peace officer, and the trial court imposed concurrent sentences for the two offenses. (Id. at pp. 779-780.)