How has section 654 of the California Criminal Code been interpreted in the context of a robbery and carjacking case?

Section 654 provides in pertinent part: "An act or omission which is made punishable in different ways by different provisions of this code may be punished under either of such provisions, but in no case can it be punished under more than one. . . ." Thus, section 654 prohibits multiple punishment for multiple offenses arising out of a single indivisible transaction. Whether a course of criminal conduct is divisible depends on the intent and objective of the actor. (Neal v. State (1960) 55 Cal.2d 11, 19.)

The question of whether the acts of which the defendant has been convicted constitute an indivisible course of conduct is primarily a factual determination made by the trial court on the basis of its express or implied findings concerning the defendant's intent and objective in committing the acts. (People v. Deloza (1998) 18 Cal.4th 585,

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594-599.) The trial court's determination is reviewed in the light most favorable to the judgment, and will not be reversed on appeal unless unsupported by the evidence presented at trial. (People v. Osband (1996) 13 Cal.4th 622, 730-731.)

b. Robbery and carjacking