After Cole v. Superior Court, is section 654 of the California Code of Civil Procedure limited to punishment for the most egregious crime?

California, United States of America


The following excerpt is from People v. Norrell, 13 Cal.4th 1, 51 Cal.Rptr.2d 429, 913 P.2d 458 (Cal. 1996):

After Cole came People v. Superior Court (Himmelsbach), supra, 186 Cal.App.3d 524, 230 Cal.Rptr. 890, which contained the first independent analysis of the merits [13 Cal.4th 20] of this question. It supports my position, and concludes, as do I, that section 654 was "meant to ensure against multiple punishment for an indivisible transgression," not to "provide courts with discretion to avoid imposition of the punishment prescribed for the most egregious offense of which the defendant stands convicted." (186 Cal.App.3d at p. 537, 230 Cal.Rptr. 890.)

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