Does section 654 of the California Criminal Code prohibit a defendant from multiple punishment for forgery and commercial burglary in cashing a forged check at a bank?

California, United States of America


The following excerpt is from People v. Bravo, F071915 (Cal. App. 2018):

In People v. Curtin (1994) 22 Cal.App.4th 528, 532, the court held that the forgery and burglary offenses were part of the same indivisible transaction, "both committed for a single criminal objective, to cash the check." And in People v. Casica (2014) 223 Cal.App.4th 320, 324, the court held that section 654 precluded multiple punishment for defendant's offenses of forgery and commercial burglary in cashing checks with forged signatures at a bank, since the defendant acted with a single objective to take money from the victim's account, and the forgery and burglary were part of the same indivisible transaction.

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