California, United States of America
The following excerpt is from People v. Buckels, B242631 (Cal. App. 2013):
Buckels concedes section 654 does not bar separate punishment for the three attempted murders or the three firearm enhancements. "There is a multiple victim exception to section 654 which allows separate punishment for each crime of violence against a different victim, even though all crimes are part of an indivisible course of conduct with a single principal objective. [Citation.] An assailant's greater culpability for intending or risking harm to more than one person precludes application of section 654. [Citation.]" (People v. Felix (2009) 172 Cal.App.4th 1618, 1630-1631.) Buckels argues section 654 bars separate punishment for the three gang enhancements, however, "because the gang enhancements are not crimes of violence as anticipated under the multiple-victim exception."
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