What is the test for sentencing a convicted rapist to two consecutive sentences?

A court also may apply any "additional criteria [not enumerated in the rules that are] reasonably related to the decision" to impose consecutive rather than concurrent sentences. (Cal. Rules of Court, rule 4.408(a).) "Articulation of one criterion for the imposition of a consecutive sentence is sufficient." (People v. Bravot (1986) 183 Cal.App.3d 93, 98.)

The trial court sentenced Buckels to consecutive terms because there were three separate victims. "[T]he naming of separate victims in separate counts is a circumstance on which a trial court may properly rely to impose consecutive sentences." (People v. Caesar (2008) 167 Cal.App.4th 1050, 1061, disapproved on other grounds in People v. Superior Court (Sparks) (2010) 48 Cal.4th 1, 18.)