People v. Eid, 59 Cal. 4th 650

Reynaldo Junior Eid and Alaor Docarmo Oliveira were charged with kidnapping for ransom after arranging transport of Ana and her son Iago from Brazil into the U.S.; prior convictions for similar conduct had been reversed for instructional error.
Victims initially went willingly to avoid police, were held in a house in Mexico, then smuggled across the border and brought to a motel by defendants. Defendants removed passports, demanded money from the husband Jefferson, and threatened relocation or involuntary labor if payment was not made.
The jury was instructed on the greater offense (kidnapping for ransom) and four lesser included offenses: kidnapping, attempted extortion, felony false imprisonment, and misdemeanor false imprisonment.
The jury acquitted defendants of kidnapping for ransom but convicted each of attempted extortion and misdemeanor false imprisonment.
The Court of Appeal struck the misdemeanor false imprisonment convictions, holding a defendant may be convicted of only one lesser included offense of a single charged crime; the California Supreme Court granted review.
The California Supreme Court reversed the Court of Appeal, holding the jury properly convicted defendants of two lesser included offenses that are both necessarily included in the charged crime but not included within each other.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a jury may convict a defendant of more than one uncharged lesser included offense of a single charged greater offense	The People argued section 1159 and related rules permit conviction of multiple necessarily included offenses when supported by evidence	Defendants argued section 1159 should be read to permit only one lesser included conviction and that Navarro forecloses multiple lesser convictions	A jury may convict on multiple lesser included offenses that are necessarily included in the charged offense (when supported by evidence); Navarro does not control because it constrains appellate modification, not jury verdicts

People v. Breverman, 19 Cal.4th 142 (explains purpose of lesser-included instructions to protect jury truth-ascertainment)
People v. Navarro, 40 Cal.4th 668 (limits appellate modification to a single lesser offense when modifying verdicts; court distinguished Navarro here)
People v. Sanders, 55 Cal.4th 731 (discusses relation of greater and lesser offenses in hierarchical inclusion contexts)
People v. Reed, 38 Cal.4th 1224 (charged offense gives notice of all lesser included offenses)
People v. Serrano, 11 Cal.App.4th 1672 (recognizes attempted extortion and false imprisonment as lesser included offenses of kidnapping)