Does Section 654, subdivision (a) of the California Criminal Code allow a defendant to be convicted of a single physical act?

Section 654, subdivision (a) provides "An act or omission that is punishable in different ways by different provisions of law shall be punished under the provision that provides for the longest potential term of imprisonment, but in no case shall the act or omission be punished under more than one provision." Application of this statute "requires a two-step inquiry, because the statutory reference to an 'act or omission' may include not only a discrete physical act but also a course of conduct encompassing several acts pursued with a single objective." (People v. Corpening (2016) 2 Cal.5th 307, 311 (Corpening).) Only if the case involves more than one act does a court consider whether the case involves a course of conduct. (Ibid.) "At step one, courts examine the facts of the case to determine whether multiple convictions are based upon a single physical act." (Id. at p. 312.) "Whether a defendant will be found to have committed a single physical act for purposes of section 654 depends on whether some action the defendant is charged with having taken separately completes the actus reus for each of the relevant criminal offenses." (Id. at p. 313.)

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