Does section 654 of the Criminal Code apply to a defendant who committed a robbery and kidnapping in the course of a carjacking?

Here, the trial court did not stay defendants' convictions for robbery and kidnapping in the course of a carjacking under section 654, and therefore impliedly found the crimes involved different intents. (People v. Coleman, supra, 48 Cal.3d at p. 162.) Defendants contend that their robbery sentence must be stayed, as the robbery and kidnapping in the course of a carjacking were incidental to one objective. Specifically, they maintain that "the carjacking, grand thefts, and robbery all constituted one continuous course of theft related conduct . . . [and] [t]he kidnap in this case was completed to facilitate the completion of the robbery and carjacking rather than for some independent purpose unrelated to the crime in progress."

Defendants have defined their intent too broadly. In People v. Trotter, the defendant took three shots at a pursuing officer during a car chase. There was a

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minute between the first and second shots, and a few seconds between the second and third. (People v. Trotter, supra, 7 Cal.App.4th at p. 366.) The court found section 654 inapplicable to the three assaults because "this was not a case where only one volitional act gave rise to multiple offenses. Each shot required a separate trigger pull. All three assaults were volitional and calculated, and were separated by periods of time during which reflection was possible. None was spontaneous or uncontrollable. '[D]efendant should . . . not be rewarded where, instead of taking advantage of an opportunity to walk away from the victim, he voluntarily resumed his . . . assaultive behavior.' " (People v. Trotter, at p. 368.)