People v. Beman
243 Cal. Rptr. 3d 802
| Cal. Ct. App. 5th | 2019Background
- Defendant Eric Beman pleaded no contest to conspiracy to commit human trafficking (count 1, Jan 2006–Apr 2013) and to two substantive human trafficking counts (counts 14, 17) involving Victim 1 in 2011.
- The charged conspiracy involved at least three victims (Victims 1–3) and numerous overt acts over seven-plus years, including beatings, forced prostitution, kidnapping, trading/selling victims, and threats with weapons.
- Defendant admitted multiple overt acts in the conspiracy plea relating to Victims 1–3, including assaults, confinement, and retrieving Victim 1 at gunpoint from a codefendant.
- The trial court sentenced defendant to 14 years for the conspiracy and two consecutive 16‑month terms for the two human‑trafficking counts, for a total of 16 years, 8 months.
- On appeal, defendant argued Penal Code § 654 barred punishment for the two substantive trafficking counts in addition to the conspiracy sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 654 bars punishment for substantive human‑trafficking counts in addition to conspiracy sentence | Prosecution: conspiracy had broader objectives and multiple victims beyond the specific 2011 trafficking of Victim 1, so separate punishment is permissible | Beman: conspiracy punishment must be stayed under § 654 because it had the same objective as the substantive offenses (trafficking of Victim 1) | Court affirmed: § 654 does not bar sentencing on both conspiracy and the two substantive counts because the conspiracy encompassed broader objectives and multiple victims over many years |
Key Cases Cited
- People v. Ramirez, 189 Cal.App.3d 603 (1987) (conspiracy punishment barred when conspiracy's only objective is the punished substantive offense)
- People v. Russo, 25 Cal.4th 1124 (2001) (discussed in Ramirez authority context)
- People v. Vargas, 91 Cal.App.4th 506 (2001) (conspiracy may be punished along with a substantive offense when conspiracy targets additional victims)
- People v. Collins, 242 Cal.App.2d 626 (1966) (conspiracy punishable with substantive offenses where conspiracy objectives extended beyond those offenses)
- People v. Amadio, 22 Cal.App.3d 7 (1971) (same: conspiracy involved more conduct than the specific substantive counts)
- People v. Briones, 167 Cal.App.4th 524 (2008) (conspiracy punishment stayed where conspiracy had no objective apart from the specific substantive drug possession offenses)