How has section 654 of the California Criminal Code been interpreted in the context of sexual assault cases?

California, United States of America


The following excerpt is from People v. Williams, E071016 (Cal. App. 2019):

Section 654 directs, "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." The purpose of this section is to "ensure that the defendant's punishment will be commensurate with his culpability." (People v. Sanders (2012) 55 Cal.4th 731, 742; People v. Jones (2012) 54 Cal.4th 350, 367.)

Where, as here, a case involves more than a single act, the application of section 654 turns on "whether that course of conduct reflects a single 'intent and objective' or multiple intents and objectives." (People v. Corpening (2016) 2 Cal.5th 307, 311.) That determination is factual, and appellate courts sustain such findings if supported by

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