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Name: People v. Martin
Case #: B177387
Court: CA Court of Appeal
District 2 DCA
Division: 2
Opinion Date: 10/24/2005

The multiple-victim exception to Penal Code section 654 applied where a defendant resisted arrest by four different officers and committed a battery on one officer. The defendant argued that the trial court erred in failing to stay execution of either his resisting arrest conviction or his conviction for battery on a police officer, arguing that both offenses were incident to one objective, i.e., escape. He further argued that the multiple-victim exception should not apply to Penal Code section 69, because resisting arrest is not framed as a crime against the individual officers. The appellate court rejected the argument, noting that other crimes that are not framed as offenses against individuals have nonetheless been held to be subject to the multiple-victim exception, such as child endangerment and making criminal threats. The multiple-victim exception properly applies to section 69, and the court did not err in imposing concurrent sentences.