multiple-victim exception in California

2025(People v. Centers (1999) 73 Cal.App.4th 84, 99 ; see Oates, at p. 1063 [“ ‘A defendant who commits an act of violence ... by a means likely to cause harm to several persons is more culpable than a defendant who harms only one person.’ ”]; People v. Solis (2001) 90 Cal.App.4th 1002, 1023 [defendant properly punished for two counts of making a criminal threat because his threatening messages were heard by two individuals].) Courts have applied the multiple victim exception in the context of shots fired at an occupied building or a vehicle under section 246.

2024Under the multiple victim exception, “ ‘ “even though a defendant entertains but a single principal objective during an indivisible course of conduct, he may be convicted and punished for each crime of violence committed against a different victim.” ’ ” (People v. Centers, supra, 73 Cal.App.4th at p. 99 , italics added.) Murder obviously qualifies as a crime of violence, and Mendez was the only victim of that crime.

2023The California Supreme Court has “long held that ‘the limitations of section 654 do not apply to crimes of violence against multiple victims.’ ” (People v. Oates (2004) 32 Cal.4th 1048, 1063 .) “Under this exception, ‘even though a defendant entertains but a single principal objective during an indivisible course of conduct, he may be convicted and punished for each crime of violence committed against a different victim.’ [Citations.] The reason for the multiple victim exception is that ‘when a defendant “ ‘commits an act of violence with the intent to harm more than one person or by means lik

2023The California Supreme Court has “long held that ‘the limitations of section 654 do not apply to crimes of violence against multiple victims.’ ” (People v. Oates (2004) 32 Cal.4th 1048, 1063 .) “Under this exception, ‘even though a defendant entertains but a single principal objective during an indivisible course of conduct, he may be convicted and punished for each crime of violence committed against a different victim.’ [Citations.] The reason for the multiple victim exception is that ‘when a defendant “ ‘commits an act of violence with the intent to harm more than one person or by means lik

2025(People v. Latimer (1993) 5 Cal.4th 1203, 1212 .) The multiple-victim exception “is applicable as long as each violent offense involves at least one different victim.” (People v. Felix (2009) 172 Cal.App.4th 1618, 1631 .) It “permits one unstayed sentence per victim of all the violent crimes the defendant commits incidental to a single criminal intent.

2025(People v. Duff (2010) 50 Cal.4th 787, 796 [“ ‘It has long been established that the imposition of concurrent sentences is precluded by section 654 [citations] because [under such a sentence] the defendant is deemed to be subjected to the term of both sentences although they are served simultaneously.’ [Citations.]”]; People v. Deloza (1998) 18 Cal.4th 585 , 591–592.) “There is a multiple victim exception to [ ] section 654 which allows separate punishment for each crime of violence against a different victim, even though all crimes are part of an indivisible course of conduct with a single pr

2015For example, although burglary of a residence in the presence of another is a violent felony (§§ 667.5, subd. (c)(21), 1170.12 subd. (b)(1)) under the Three Strikes law, burglary “standing alone is not a violent crime for purposes of the multiple victim exception.” (People v. Centers (1999) 73 Cal.App.4th 84, 99 [ 86 Cal.Rptr.2d 151 ]; see People v. Miller, supra, 18 Cal.3d at p. 886 [burglary with infliction *116 of great bodily injury is an act of violence].) We conclude that Neal’s “act of violence,” formulated years before the Three Strikes law, is untethered to “violent felony” under Thre

2015(People v. Latimer (1993) 5 Cal.4th 1203, 1212 ; People v. Miller (1977) 18 Cal.3d 873, 885 .) Under this so-called multiple victim exception, multiple punishments for violent crimes against separate individuals is proper even when the 9 crimes are part of an indivisible course of conduct.

2025When the defendant spotted Hooker driving a car, with Kimberly McLean and Derrick Ross as passengers, he fired four or five shots at Hooker’s car; one shot struck Ross. [Citation.] The defendant pleaded guilty to assault on Ross with a deadly weapon and shooting at an occupied motor vehicle [Citation], and was given a separate, unstayed sentence for each.” (Garcia, supra, 32 Cal.App.4th at p. 1782 .) The appellate court upheld the sentencing, applying the multiple victim exception to section 654.

2023Under the multiple victim exception, “ ‘even though a defendant entertains but a single principal objective during an indivisible course of conduct, he may be convicted and punished for each crime of violence committed against a different victim.’ ” (People v. Garcia (1995) 32 Cal.App.4th 1756, 1781 .) “An assailant’s greater culpability for intending or risking harm to more than one person precludes application of section 654.” (People v. Felix (2009) 172 Cal.App.4th 1618, 1631 (Felix).) Titus contends the record does not support applying the multiple victim exception to his offense of shooti

2025(People v. Duff (2010) 50 Cal.4th 787, 796 [“ ‘It has long been established that the imposition of concurrent sentences is precluded by section 654 [citations] because [under such a sentence] the defendant is deemed to be subjected to the term of both sentences although they are served simultaneously.’ [Citations.]”]; People v. Deloza (1998) 18 Cal.4th 585 , 591–592.) “There is a multiple victim exception to [ ] section 654 which allows separate punishment for each crime of violence against a different victim, even though all crimes are part of an indivisible course of conduct with a single pr

2023Porter, in contrast, seems to suggest that the timing of the defendant’s intent is critical.” (Smith, supra, 18 Cal.App.4th at p. 1198 , fn. omitted.) 33. supra, 8 Cal.3d at pp. 630–631; People v. Barrios, supra, 61 Cal.App.5th at pp. 177–178; Smith, supra, 18 Cal.App.4th at pp. 1194–1195; Porter, supra, 194 Cal.App.3d at pp. 36– 37), or because the crimes committed against multiple victims resulted in multiple convictions for the same offense (People v. Lewis, supra, 43 Cal.4th at p. 519 ; People v. Knowles, supra, 35 Cal.2d at pp. 177–178). “‘The multiple victim exception, simply stated, per

2023(People v. Pantoja (2004) 122 Cal.App.4th 1, 16 .) Additionally, the fact that felony child endangerment is not listed in section 667.5 is not dispositive. “[W]hether a crime constitutes an act of violence that qualifies for the multiple-victim exception to section 25 654 depends upon whether the crime . . . is defined to proscribe an act of violence against the person.” (People v. Hall (2000) 83 Cal.App.4th 1084, 1092 .) The crime of grossly negligent discharge of a firearm prohibits any person from willfully discharging a firearm in a grossly negligent manner which could result in injury or

2023(See People v. Hall, supra, 83 Cal.App.4th at p. 1089 [a criminal act qualifies for the multiple-victim exception where the crime of which defendant was convicted was defined by statute to proscribe an act of violence committed “ ‘with the intent to harm’ ” or “ ‘by means likely to cause harm’ ” to a person], overruled on another ground in People v. Correa, supra, 54 Cal.4th at pp. 343-344.) Additionally, willful discharge of a firearm with gross negligence in violation of section 246.3 poses a sufficient danger to human life to constitute an act of violence because it presupposes that there a

2020However, while not expressly naming the multiple victim exception, the 14 Akins court made clear that the result would have been the same had the violent crimes taken place in a single episode when it pointed out that “[m]ultiple acts of violence committed against separate victims may be separately punished, even when they are for the same intent and during the same transaction.” ( Akins, supra, 56 Cal.App.4th at pp. 340–341, citing Perez, supra, 23 Cal.3d at p. 553 .) We conclude that section 654 provides no legal basis to stay the section 186.22, subdivision (b)(1)(C) enhancement with respec

2020However, while not expressly naming the multiple victim exception, the 14 Akins court made clear that the result would have been the same had the violent crimes taken place in a single episode when it pointed out that “[m]ultiple acts of violence committed against separate victims may be separately punished, even when they are for the same intent and during the same transaction.” ( Akins, supra, 56 Cal.App.4th at pp. 340–341, citing Perez, supra, 23 Cal.3d at p. 553 .) We conclude that section 654 provides no legal basis to stay the section 186.22, subdivision (b)(1)(C) enhancement with respec

2022(People v. Neal (1960) 55 Cal.2d 11, 20 , disapproved on other grounds in People v. Correa (2012) 54 Cal.4th 331, 334 .) In People v. Hall (2000) 83 Cal.App.4th 1084, 1091 , this court surveyed the application of the multiple-victim exception to various crimes, and concluded: “[I]n each case where the multiple-victim exception was satisfied, the qualifying crime . . . was defined to proscribe an act of violence committed against the person.” (Ibid., italics omitted.) The question here, therefore, is whether the act of dissuading a witness, which defendant directed at both R.S. and L.D., was “a

2022(People v. Harrison (1989) 48 Cal.3d 321, 335 (Harrison).) “If all of the offenses were incident to one objective, the defendant may be punished for any one of such offenses but not for more than one.” (Neal v. State of California (1960) 55 Cal.2d 11, 19 , overruled in part on another ground in People v. Correa (2012) 54 Cal.4th 331, 341 (Correa).) There is, however, a multiple victim exception to section 654.

2016(Martin, supra, 133 Cal.App.4th at p. 780 .) On appeal, he argued the trial court should have stayed execution of sentence on either the resisting arrest conviction or the battery on a police officer conviction because “both offenses were incident to his sole objective to escape.” (Ibid.) While the appellate court agreed with Martin that “his sole objective in both resisting arrest and committing battery on a police officer was to free himself’ (id. at p. 781), it affirmed the trial court’s sentencing decision based on the multiple-victim exception (id. at pp. 782-783).

2015Under this exception, ‘even though a defendant entertains but a single principal objective during an indivisible course of conduct, he may be convicted and punished for each crime of violence committed against a different victim.’ [Citations.]” (People v. Garcia (1995) 32 Cal.App.4th 1756, 1781 .) “ ‘ “[W]hether a crime constitutes an act of violence that qualifies for the multiple-victim exception to section 654 depends upon whether the crime . . . is defined to proscribe an act of violence against the person.” ’ [Citation.]” (People v. Martin (2005) 133 Cal.App.4th 776, 782 (Martin).) In a s

2025(People v. Centers (1999) 73 Cal.App.4th 84, 99 ; see Oates, at p. 1063 [“ ‘A defendant who commits an act of violence ... by a means likely to cause harm to several persons is more culpable than a defendant who harms only one person.’ ”]; People v. Solis (2001) 90 Cal.App.4th 1002, 1023 [defendant properly punished for two counts of making a criminal threat because his threatening messages were heard by two individuals].) Courts have applied the multiple victim exception in the context of shots fired at an occupied building or a vehicle under section 246.

2022The court explained that, to obtain a conviction for making a terrorist threat, the prosecution was required to prove the victim was injured by experiencing “sustained fear.” Thus, making a terrorist threat “constitute[d] a crime of psychic violence” that qualified as an act of violence under the multiple-victim exception of section 654. ( Solis, supra, 90 Cal.App.4th at pp. 1023- 9 1024.) In that case, the act of violence was the statutory element of inflicting sustained fear.

2013(People v. Oates, supra, 32 Cal.4th at p. 1063 .) The multiple victim exception to section 654 is based on the rationale that "when a defendant '"commits an act of violence with the intent to harm more than one person or by means likely to cause harm to several persons," his greater culpability precludes application of section 654.'" (People v. McFarland (1989) 47 Cal.3d 798, 803 ; see also People v. Centers (1999) 73 Cal.App.4th 84, 99 ; People v. Garcia, supra, 32 Cal.App.4th at p. 1781 .) "[W]hether a crime constitutes an act of violence that qualifies for the multiple- victim exception to

2013(People v. Oates, supra, 32 Cal.4th at p. 1063 .) The multiple victim exception to section 654 is based on the rationale that "when a defendant '"commits an act of violence with the intent to harm more than one person or by means likely to cause harm to several persons," his greater culpability precludes application of section 654.'" (People v. McFarland (1989) 47 Cal.3d 798, 803 ; see also People v. Centers (1999) 73 Cal.App.4th 84, 99 ; People v. Garcia, supra, 32 Cal.App.4th at p. 1781 .) "[W]hether a crime constitutes an act of violence that qualifies for the multiple- victim exception to

2023As explained by People v. Pantoja (2004) 122 Cal.App.4th 1 , “ ‘A defendant who commits an act of violence with the intent to harm more than one person or by a means likely to cause harm to several persons is more culpable than a defendant who harms only one person.

2023(People v. Pantoja (2004) 122 Cal.App.4th 1, 16 .) Additionally, the fact that felony child endangerment is not listed in section 667.5 is not dispositive. “[W]hether a crime constitutes an act of violence that qualifies for the multiple-victim exception to section 25 654 depends upon whether the crime . . . is defined to proscribe an act of violence against the person.” (People v. Hall (2000) 83 Cal.App.4th 1084, 1092 .) The crime of grossly negligent discharge of a firearm prohibits any person from willfully discharging a firearm in a grossly negligent manner which could result in injury or

2023Porter, in contrast, seems to suggest that the timing of the defendant’s intent is critical.” (Smith, supra, 18 Cal.App.4th at p. 1198 , fn. omitted.) 33. supra, 8 Cal.3d at pp. 630–631; People v. Barrios, supra, 61 Cal.App.5th at pp. 177–178; Smith, supra, 18 Cal.App.4th at pp. 1194–1195; Porter, supra, 194 Cal.App.3d at pp. 36– 37), or because the crimes committed against multiple victims resulted in multiple convictions for the same offense (People v. Lewis, supra, 43 Cal.4th at p. 519 ; People v. Knowles, supra, 35 Cal.2d at pp. 177–178). “‘The multiple victim exception, simply stated, per

2000(In re Ford, supra, 66 Cal.2d 183 ; accord, In re Wright, supra, 65 Cal.2d at p. 656 .) In contrast, even though it holds the potential for violence, “[b]urglary, standing alone, is not a violent crime for purposes of the multiple victim exception.” (People v. Centers (1999) 73 Cal.App.4th 84, 99 [ 86 Cal.Rptr.2d 151 ]; accord, People v. Miller, supra, 18 Cal.3d at p. 886 .) Burglary, as defined, simply does not require an act of violence committed with the intent to harm or by means likely to harm a person.

2023Porter, in contrast, seems to suggest that the timing of the defendant’s intent is critical.” (Smith, supra, 18 Cal.App.4th at p. 1198 , fn. omitted.) 33. supra, 8 Cal.3d at pp. 630–631; People v. Barrios, supra, 61 Cal.App.5th at pp. 177–178; Smith, supra, 18 Cal.App.4th at pp. 1194–1195; Porter, supra, 194 Cal.App.3d at pp. 36– 37), or because the crimes committed against multiple victims resulted in multiple convictions for the same offense (People v. Lewis, supra, 43 Cal.4th at p. 519 ; People v. Knowles, supra, 35 Cal.2d at pp. 177–178). “‘The multiple victim exception, simply stated, per

2015(Deloza, supra, 18 Cal.4th at p. 592; People v. Miller (1977) 18 Cal.3d 873, 885 [ 135 Cal.Rptr. 654 , 558 P.2d 552 ] (Miller), overruled on other grounds as stated in People v. Oates (2004) 32 Cal.4th 1048, 1067, fn. 8 [ 12 Cal.Rptr.3d 325 , 88 P.3d 56 ].) Under the multiple victim exception, “ ‘ “even though a defendant entertains but a single principal objective during an indivisible course of conduct, he [or she] may be convicted and punished for each crime of violence committed against a different victim.” [Citations.]’ ” (Centers, supra, 73 Cal.App.4th at p. 99 .) “The robbery of a victi

2023Imposition of unstayed sentences for one aggravated kidnapping and one aggravated robbery is “consistent with the rationale of the multiple- victim exception, which is to recognize the greater culpability of a defendant whose actions harm or threaten to harm multiple people.” (In re L.J., supra, 72 Cal.App.5th at p. 46, citing Correa, supra, 54 Cal.4th at p. 341 .) Therefore, we affirm the trial court’s imposition of sentences for aggravated kidnapping and aggravated robbery under section 654.

2023Imposition of unstayed sentences for one aggravated kidnapping and one aggravated robbery is “consistent with the rationale of the multiple- victim exception, which is to recognize the greater culpability of a defendant whose actions harm or threaten to harm multiple people.” (In re L.J., supra, 72 Cal.App.5th at p. 46, citing Correa, supra, 54 Cal.4th at p. 341 .) Therefore, we affirm the trial court’s imposition of sentences for aggravated kidnapping and aggravated robbery under section 654.

2024(Centers, at p. 90.) The court noted that neither the information nor the verdicts specified a particular victim of the burglary and its firearm use enhancement (id. at pp. 100–101), and in that circumstance “the trial court is entitled to make any necessary factual findings not already made by the jury.” (Id. at p. 101, italics added.) Specifically, Centers correctly pointed out “a number of cases have upheld the application of the multiple victim exception based on evidence of multiple victims, without considering whether the identities of those victims had been pleaded.” (Ibid., citing Peop

2014Ordinarily, in determining whether Penal Code section 654 applies, the trial court is entitled to make any necessary factual findings not already made by the jury. [Citation.]” (Id. at p. 101.) Centers correctly pointed out that “a number of cases have upheld the application of the multiple victim exception based on evidence of multiple victims, without considering whether the identities of those victims had been pleaded.” (Ibid., citing People v. Cruz (1995) 38 Cal.App.4th 427 , 434–435 6 and People v. Guiterrez (1992) 10 Cal.App.4th 1729 , 1736–1737.) As in Centers, here the trial court’s im

2023Porter, in contrast, seems to suggest that the timing of the defendant’s intent is critical.” (Smith, supra, 18 Cal.App.4th at p. 1198 , fn. omitted.) 33. supra, 8 Cal.3d at pp. 630–631; People v. Barrios, supra, 61 Cal.App.5th at pp. 177–178; Smith, supra, 18 Cal.App.4th at pp. 1194–1195; Porter, supra, 194 Cal.App.3d at pp. 36– 37), or because the crimes committed against multiple victims resulted in multiple convictions for the same offense (People v. Lewis, supra, 43 Cal.4th at p. 519 ; People v. Knowles, supra, 35 Cal.2d at pp. 177–178). “‘The multiple victim exception, simply stated, per

2022(People v. Oates (2004) 32 Cal.4th 1048, 1063 ; In re Ford (1967) 66 Cal.2d 183, 184 ; People v. Reyes-Tornero (2016) 4 Cal.App.5th 368, 377 .) “The multiple victim exception, simply stated, permits one unstayed sentence per victim of all the violent crimes the defendant commits incidental to a single criminal intent.” (People v. Garcia (1995) 32 Cal.App.4th 1756, 1784 .) T.’s friend, at whose vehicle Carr shot, and Frank, at whose house Carr shot, were not victims of any of the other crimes for which the court sentenced him to prison.

2022(Centers, supra, 73 Cal.App.4th at p. 99 ; see People v. Cardenas, supra, 239 Cal.App.4th at pp. 230-231, 233.) “To preclude application of section 654, however, each of the crimes must have involved at least one different victim.” (People v. Cardenas, supra, at p. 230 ; accord, People v. Garcia (1995) 32 Cal.App.4th 1756, 1784 [“The multiple victim exception, simply stated, permits one unstayed sentence per victim of all the violent crimes the defendant commits incidental to a single criminal intent.”].) In Centers, we concluded burglary was a violent crime that supported application of the m

2022(Centers, supra, 73 Cal.App.4th at p. 99 ; see People v. Cardenas, supra, 239 Cal.App.4th at pp. 230-231, 233.) “To preclude application of section 654, however, each of the crimes must have involved at least one different victim.” (People v. Cardenas, supra, at p. 230 ; accord, People v. Garcia (1995) 32 Cal.App.4th 1756, 1784 [“The multiple victim exception, simply stated, permits one unstayed sentence per victim of all the violent crimes the defendant commits incidental to a single criminal intent.”].) In Centers, we concluded burglary was a violent crime that supported application of the m

2023(People v. Harrison (1989) 48 Cal.3d 321, 335 .) When interpreting the scope and meaning of the multiple victim exception, we apply a de novo standard of review.

2023(People v. Harrison (1989) 48 Cal.3d 321, 335 .) When interpreting the scope and meaning of the multiple victim exception, we apply a de novo standard of review.

2014The 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.

2012(See People v. Davey (2005) 133 Cal.App.4th 384 [ 34 Cal.Rptr.3d 811 ] (Davey); People v. Hall (2000) 83 Cal.App.4th 1084 [ 100 Cal.Rptr.2d 279 ] (Hall).) In Davey, supra, 133 Cal.App.4th 384 , the Court of Appeal held that under section 654, “a single act of indecent exposure constitutes only one crime for the purpose of sentencing, regardless of the number of people who witness it.” (Davey, at p. 387.) The court further held that “indecent exposure is not a violent crime for the purpose of the multiple-victim exception under section 654 . . . .” (Id. at p. 392.) Citing the Neal footnote, the

2014Section 654 is not '. . . applicable where . . . one act has two results each of which is an act of violence against the person of a separate individual.' " ( Neal, supra, 55 Cal.2d at pp. 20-21, quoting People v. Brannon, supra 70 Cal.App. at pp. 235- 236, italics added.) Because the crime of which Ward was convicted (1) involved a separate victim and (2) involved (by statutory definition) the employment of "means of force likely to produce great bodily injury," the crime appears to fall within Neal's rationale for applying the multiple victim exception.

2000Section 654 is not ' . . applicable where . . . one act has two results each of which is an act of violence against the person of a separate individual.’ ” ( Neal, supra, 55 Cal.2d at pp. 20-21, quoting People v. Brannon (1924) 70 Cal.App. 225, 235-236 [ 233 P. 88 ].) A review of the relevant case law since Neal reveals that in each case where a criminal act qualified for the multiple-victim exception, the criminal act—that is, the crime of which defendant was convicted, including any allegations in enhancement—was defined by statute to proscribe an act of violence against the person, that is,

2023(See People v. Centers (1999) 73 Cal.App.4th 84, 101 .) An appellate court will sustain a trial court’s implied factual determination in the application of section 654 if supported by substantial evidence. ( Osband, supra, 13 Cal.4th at pp. 730-731.) In this case, there is substantial evidence to support the trial court’s conclusion that the multiple victim exception applied to the misdemeanor child endangerment offense. 40 While Johnson’s acts of violence were not directed at the child, that makes no difference.

2023(See People v. Centers (1999) 73 Cal.App.4th 84, 101 .) An appellate court will sustain a trial court’s implied factual determination in the application of section 654 if supported by substantial evidence. ( Osband, supra, 13 Cal.4th at pp. 730-731.) In this case, there is substantial evidence to support the trial court’s conclusion that the multiple victim exception applied to the misdemeanor child endangerment offense. 40 While Johnson’s acts of violence were not directed at the child, that makes no difference.

2014Under the multiple-victim exception to section 654, “even though a defendant entertains but a single principal objective during an indivisible course of conduct, he may be convicted and punished for each crime of violence committed against a different victim.” (People v. Ramos (1982) 30 Cal.3d 553, 587 , reversed on other grounds in California v. Ramos (1983) 463 U.S. 992 .) In this case, defendant did not meet the threshold requirement of entertaining a single objective in an indivisible course of action, so it is unnecessary to decide whether the exception would apply. 6 Calculation of Custo

2013(People v. Oates (2004) 32 Cal.4th 1048, 1063 ; People v. Garcia, supra, 32 Cal.App.4th at p. 1781 ; People v. Deloza, supra, 18 Cal.4th at p. 592 ["Section 654 does not . . . preclude multiple punishment when the defendant's violent act injures different victims."].) Under this exception, a defendant may be convicted and punished for each crime of violence committed against a different victim "even though a defendant entertains but a single principal objective during an indivisible course of conduct." (People v. Ramos (1982) 30 Cal.3d 553, 587 , revd. on other grounds in California v. Ramos (

2025(People v. Latimer (1993) 5 Cal.4th 1203, 1212 .) The multiple-victim exception “is applicable as long as each violent offense involves at least one different victim.” (People v. Felix (2009) 172 Cal.App.4th 1618, 1631 .) It “permits one unstayed sentence per victim of all the violent crimes the defendant commits incidental to a single criminal intent.

2015(People v. Latimer (1993) 5 Cal.4th 1203, 1212 ; People v. Miller (1977) 18 Cal.3d 873, 885 .) Under this so-called multiple victim exception, multiple punishments for violent crimes against separate individuals is proper even when the 9 crimes are part of an indivisible course of conduct.

2015It is not clear that there were any victims on the forgery convictions, since no victims were named in the information and 14 victims, “the multiple victim exception to section 654 only applies to crimes of violence against persons, not crimes against property.” (People v. Kurtenbach, supra, (2012) 204 Cal.App.4th at p. 1290 ; see People v. Correa (2012) 54 Cal.4th 331, 341 [“section 654 does not apply to crimes of violence against multiple victims”].) The forgeries and thefts were not crimes of violence.

2015Accordingly, the multiple-victim exception to section 654 does not apply because vandalism is not a crime of violence against a person.” ( Kurtenbach, supra, 204 Cal.App.4th at pp. 1290-1291.) Here, Donley’s assault conviction and the vandalism conviction involving the studio apartment owned by Crisan were based on Donley’s conduct in driving his truck into the doorway of the studio.