California, United States of America
The following excerpt is from People v. Stewart, E057199 (Cal. App. 2014):
The People appear be claiming that the multiple victim exception to section 654 applies here. However, the multiple victim exception is inapplicable. The multiple victim exception to section 654 essentially states that "when multiple victims are targeted by a single episode of violent criminal conduct, the perpetrator may be punished separately for the crimes committed against each victim." (People v. Davey (2005) 133 Cal.App.4th 384, 390, italics added.) Here, while there were multiple victims, Mendoza and Olivera were the victims of separate courses of conduct by defendant. Within those separate courses of conductthe false imprisonment and robbery of Mendoza, and the
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false imprisonment and robbery of Oliverasection 654 applies to prevent multiple punishment for a single occurrence.
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