People v. Ahmed, 264 P.3d 822

Defendant Ahmed shot his girlfriend in the stomach with a .38 handgun, leading to a conviction for assault with a firearm (§ 245, subd. (a)(2)).
The jury found true enhancements for personal use of a firearm (§ 12022.5, subd. (a)) and infliction of great bodily injury (§ 12022.7, subd. (e)).
The trial court sentenced Ahmed to 13 years: upper term for assault, plus firearm and great-bodily-injury enhancements, plus two consecutive prior prison terms.
The Court of Appeal held Penal Code § 654 barred both enhancements for the same act and stayed the firearm-use enhancement, reducing the sentence.
The People petitioned for review to decide how § 654 interacts with multiple enhancements and whether both enhancements may be imposed.
Key statutory context centers on § 1170.1 (f) and (g), which govern multiple weapon and multiple great-bodily-injury enhancements for a single offense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 654 bars multiple enhancements for a single act.	Ahmed argues § 654 bars multiple enhancements arising from the same act.	Ahmed contends § 654 requires staying or limiting enhancements when tied to one act.	§ 654 does not control when a specific statute permits multiple enhancements.
Whether § 1170.1(f)-(g) allows both a weapon enhancement and a great-bodily-injury enhancement for the same offense.	The People contend both enhancements may apply if both facts are present.	Ahmed argues only the greatest enhancement should apply if § 1170.1 governs.	Yes; § 1170.1(f)-(g) permits both a weapon enhancement and a great-bodily-injury enhancement for the same offense.

People v. Coronado, 12 Cal.4th 145 (Cal. 1996) (enhancements may differ in focus; distinguishes offender vs. offense aspects)
People v. Rodriguez, 47 Cal.4th 501 (Cal. 2009) (courts may resolve § 654 interaction by examining specific statutes)
People v. Oates, 32 Cal.4th 1048 (Cal. 2004) (utilized statutory approach to § 654/enhancements)
People v. Boerner, 120 Cal.App.3d 506 (Cal. App. 1981) (early interpretation of § 1170.1(e) and dual enhancements)
People v. Ferrell, 218 Cal.App.3d 828 (Cal. App. 1990) (illustrates restrictions on dual enhancements under pre-1997 framework)
People v. Wynn, 184 Cal.App.4th 1210 (Cal. App. 2010) (discussion of § 654 application to enhancements)
People v. Chaffer, 111 Cal.App.4th 1037 (Cal. App. 2003) (treats § 654 as implied exception to enhancements in some contexts)
People v. Masbruch, 13 Cal.4th 1001 (Cal. 1996) (explores § 654 interplay with enhancements)
People v. Hernandez, 46 Cal.3d 194 (Cal. 1988) (distinguishes offense vs. offender enhancements)
People v. Reeves, 91 Cal.App.4th 14 (Cal. App. 2000) (discusses § 654 and enhancements)
People v. Arndt, 76 Cal.App.4th 387 (Cal. App. 1999) (applies § 654 to enhancements context)