California, United States of America
The following excerpt is from People v. Aleman, F063601 (Cal. App. 2012):
In People v. Higareda (1994) 24 Cal.App.4th 1399, the defendant robbed two victims, then fired a shotgun in the direction of their car, in which a third person was a passenger. On appeal, the defendant contended firing the shotgun was part of a course of conduct indivisible from the robbery; hence, it could not be separately punished. The Court of Appeal disagreed, reasoning that the third person in the car was not a robbery victim, and so the defendant could be separately punished for endangering her by his violent crime. (Id. at p. 1413.)
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