If a defendant has multiple objectives for purposes of section 654 of the California Criminal Code, can he be punished for each of the objectives?

California, United States of America


The following excerpt is from The People v. Ruiz, D053520, No. SCE268001 (Cal. App. 2010):

The trial court has broad discretion in determining the factual issue of whether a defendant has multiple objectives for purposes of section 654, and on appeal we will uphold the court's express or implied finding that a defendant held multiple criminal objectives if it is supported by the evidence. (See People v. Osband (1996) 13 Cal.4th 622, 730; People v. Beamon (1973) 8 Cal.3d 625, 636-639.)

If the evidence discloses the defendant's acts were independent and divisible, then "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." (People v. Perez (1979) 23 Cal.3d 545, 551, fn. omitted.) Further, because the purpose of section 654's prohibition against multiple punishment is to ensure that punishment is commensurate with culpability, courts have recognized that an offense committed to achieve another offense may "at some point... become so extreme [that it]

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