Is a defendant who commits a violent crime against several victims more culpable than a violent offender who commits violent crimes against one person more than one?

A defendant who commits a violent crime against several victims is more culpable that a defendant who commits a violent crime against one person, regardless of his intent or objective. (Oates, supra, 32 Cal.4th at p. 1063.) The multiple victim exception promotes section 654's purpose that a defendant's punishment will be commensurate with his culpability. (Oates, at p. 1063.) Likewise, multiple enhancements ensure that a defendant will not be treated less severely because he chooses to rob several victims to benefit his gang rather than just one victim. (Cf. People v. King, supra, 5 Cal.4th at pp. 73-74.) We conclude that where there were multiple victims, each robbery conviction is subject to a gang enhancement.

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