People v. Corpening, 211 Cal. Rptr. 3d 863

Early morning, July 22, 2012: assailants forcefully took Walter Schmidt Sr.’s van (containing about $70,000 in rare coins) at gunpoint; victim was dragged and the van driven away.
Corpening pleaded guilty to carjacking (§ 215), robbery (§ 211), assault with a deadly weapon, receiving stolen property, and witness intimidation; the charging allegations for carjacking and robbery rested on the same forceful taking of the vehicle and its contents.
At sentencing the prosecutor recommended staying the robbery term under Penal Code § 654; the trial court instead imposed a consecutive one‑year robbery term to the carjacking term.
The Court of Appeal affirmed, applying Neal’s multiple‑objective test and finding distinct intents (steal coins vs. take vehicle to escape).
The California Supreme Court granted review, applied the two‑step § 654 framework from People v. Jones, and held that where the same physical act completes the actus reus of multiple crimes, multiple punishment is barred; it ordered the robbery term stayed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the forceful taking of the van was a single "act" under Penal Code § 654, barring punishment for both carjacking and robbery	The People argued the prosecution could punish both offenses because the taking involved discrete physical acts and separate objectives	Corpening argued the single forceful taking accomplished the actus reus of both offenses, so § 654 forbids multiple punishment	The Court held the single forceful taking completed the actus reus of both robbery and carjacking; § 654 bars punishment under both statutes, so robbery term must be stayed

Neal v. State of California, 55 Cal.2d 11 (1960) (explains multiple‑act vs. single‑objective analysis under § 654)
People v. Jones, 54 Cal.4th 350 (2012) (clarifies two‑step § 654 framework: determine single physical act first, then consider multiple objectives only if course of conduct)
People v. Mesa, 54 Cal.4th 191 (2012) (holds act completing actus reus controls whether multiple punishment is barred)
In re Hayes, 70 Cal.2d 604 (1969) (overruled by Jones; had allowed multiple punishment for different aspects of same conduct)
People v. Dominguez, 38 Cal.App.4th 410 (1995) (carjacking and robbery based on the same forceful taking constitute a single act for § 654 purposes)
People v. Vargas, 59 Cal.4th 635 (2014) (treats robbery and carjacking based on the same act as not separate strikes)