California, United States of America
The following excerpt is from People v. Adair, D059701, Super. Ct. No. SCD228574 (Cal. App. 2012):
Whether a transaction is divisible so as to allow multiple punishment under section 654 depends on whether the defendant had an independent objective for each offense. (People v. Harrison, supra, 48 Cal.3d at p. 335.) "[I]f all of the offenses were merely incidental to, or were the means of accomplishing or facilitating one objective, [a] defendant may be found to have harbored a single intent and therefore may be punished only once." (Ibid.) In contrast, if the defendant "harbored 'multiple criminal objectives,' which were independent of and not merely incidental to each other, he may be punished for each statutory violation committed in pursuit of each objective, 'even though the violations shared common acts or were parts of an otherwise indivisible course of conduct.' " (Ibid.)
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