California, United States of America
The following excerpt is from People v. Coleman, B254073 (Cal. App. 2015):
"'Section 654 has been applied not only where there was but one "act" in the ordinary sense . . . but also where a course of conduct violated more than one statute and the problem was whether it comprised a divisible transaction which could be punished under more than one statute within the meaning of section 654.' [Citation.]" (Neal v. State of California (1960) 55 Cal.2d 11, 19, disapproved on other grounds as stated in People v. Sanders (2012) 55 Cal.4th 731, 742.)
To determine "'[w]hether a course of criminal conduct is divisible and therefore gives rise to more than one act within the meaning of section 654 depends on the intent and objective of the actor. If all of the offenses were incident to one objective, the defendant may be punished for any one of such offenses but not for more than one.' [Citation.] [C]ases have sometimes found separate objectives when the objectives were either (1) consecutive even if similar or (2) different even if simultaneous. In those cases, multiple punishment was permitted. [Citation.]" (People v. Britt, supra, 32 Cal.4th at pp. 951-952.)
Section 654 is applicable "in those instances wherein the accused entertained a principal objective to which other objectives, if any, were merely incidental." (People v. Beamon (1973) 8 Cal.3d 625, 639, fn. omitted.) "[I]f the evidence discloses that a defendant entertained multiple criminal objectives which were independent of and not merely incidental to each other, he may be punished for the independent violations committed in pursuit of each objective even though the violations were parts of an otherwise indivisible course of conduct. [Citations.]" (People v. Perez (1979) 23 Cal.3d 545, 551-552, fn. omitted.) "[A] course of conduct divisible in time, although directed to one objective, may give rise to multiple violations and punishment." (People v. Beamon, supra, 8 Cal.3d at p. 639, fn. 11.)
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