People v. Statler CA1/2, A142141

On Dec. 4, 2012, Charles Statler and two others seized Sheri Reese at gunpoint/carjacked her, forced her into an SUV, and took her to multiple locations over ~8 hours while threatening rape, mutilation, and death.
Statler initially demanded ~2 pounds of marijuana kept in Reese’s garage safe; when she could not or would not produce it, he then demanded information about a separate alleged theft of ~$150,000 in marijuana.
The group repeatedly threatened and coerced Reese (including at one point applying a tool to her fingers), drove to her workplace property, a fast-food restaurant, a residential center, and back to her home, where she ultimately retrieved the two pounds.
Statler was tried by jury, convicted of kidnapping (Pen. Code § 207), carjacking (§ 215), unlawfully taking/ driving a vehicle (Veh. Code § 10851), and making criminal threats (§ 422); enhancement allegations were found true.
At sentencing the court imposed consecutive terms for kidnapping, carjacking (principal term), and criminal threats, staying the vehicle conviction; Statler appealed solely arguing Penal Code § 654 required stays of punishment for kidnapping and criminal threats because the acts were one indivisible course of conduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 654 bars multiple punishments for kidnapping and criminal threats	The People argued the crimes were divisible: distinct objectives and separate volitional acts over time supported consecutive sentences	Statler argued all offenses were part of one continuous course of conduct with a single objective—to obtain information about stolen marijuana—so § 654 requires a stay of additional punishments	The court held substantial evidence supported multiple, separate objectives and opportunities for reflection; § 654 did not bar consecutive punishment for kidnapping, carjacking, and criminal threats

Neal v. State of California, 55 Cal.2d 11 (1960) (established intent/objective test for § 654)
People v. Harrison, 48 Cal.3d 321 (1989) (multiple volitional acts and separate objectives permit multiple punishment)
People v. Latimer, 5 Cal.4th 1203 (1993) (limitations and refinements to Neal rule)
People v. Correa, 54 Cal.4th 331 (2012) (section 654 does not bar multiple punishment for multiple violations of same statute)
People v. Trotter, 7 Cal.App.4th 363 (1992) (separate trigger pulls over brief interval support separate punishments)
People v. Britt, 32 Cal.4th 944 (2004) (single objective—avoid detection—required stay under § 654)
People v. Surdi, 35 Cal.App.4th 685 (1995) (separated, reflective acts justified separate punishments)