Can a defendant be punished for both a robbery and a burglary under section 654 of the California Criminal Code?

Generally, "section 654 bars punishment for both burglary and robbery where the sole purpose of the burglary was to effectuate the robbery." (People v. Smith (1985) 163 Cal.App.3d 908, 912.) Thus, unless the multiple victim exception applies, defendants could not be separately punished for both the robbery and burglary.

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"Under the multiple victim exception, '"'even though a defendant entertains but a single principal objective during an indivisible course of conduct, he [or she] may be convicted and punished for each crime of violence committed against a different victim.' [Citations.]"' [Citation.] 'The robbery of a victim at gunpoint has been held to be an act of violence such as to preclude application of section 654 in the case of multiple convictions involving multiple victims.' [Citations.] Burglary may also be treated as a crime of violence when the defendant personally used a firearm in committing the offense. [Citation.] To preclude application of section 654, however, each of the crimes must have involved at least one different victim." (People v. Cardenas (2015) 239 Cal.App.4th 220, 230.)