In People v. Foster (1988) 201 Cal.App.3d 20, imposition of consecutive sentences for robbery and false imprisonment was upheld where the defendant and his accomplice robbed a convenience store and, after obtaining all the money, forced the three victims into the store cooler and blocked their exit with a cart. The reviewing court rejected the defendant's claim that the false imprisonment of the victims was merely incidental to the robbery. "The imprisonment of the victims occurred after the robbers had obtained all of the money, and therefore was not necessary or incidental to committing the robbery. Locking the victims in the store cooler was potentially dangerous to their safety and health. It is analogous to a needless or vicious assault committed after a robbery, which has long been held separately punishable and distinguishable from an assault which is merely incidental to robbery." (Id. at pp. 27-28.) The defendants were convicted of robbery and false imprisonment, and sentenced to consecutive terms for those offenses. The Court of Appeal rejected the claim that section 654 barred separate punishment on the false imprisonment. It concluded that "[t]he imprisonment of the victims occurred after the robbers had obtained all of the money, and therefore was not necessary or incidental to committing the robbery." (Id. at p. 27.) The Foster court added that the false imprisonment was "analogous to a needless or vicious assault committed after a robbery . . . ." (Ibid.) The Court upheld multiple punishments for robbery and false imprisonment where the defendant and an accomplice robbed a convenience store and locked the clerks and a customer in the store's cooler. (Id. at pp. 23, 28.) The court rejected the defendant's claim that the false imprisonment was merely incidental to the robbery, explaining: "The imprisonment of the victims occurred after the robbers had obtained all of the money, and therefore was not necessary or incidental to committing the robbery. Locking the victims in the store cooler was potentially dangerous to their safety and health. It is analogous to a needless or vicious assault committed after a robbery, which has long been held separately punishable and distinguishable from an assault which is merely incidental to robbery." (Id. at pp. 27-28.) In sum, the defendant and a confederate were convicted of robberies of three commercial establishments on separate occasions. After the men had completed their last robbery, they locked the robbery victim, another store employee and that employee's spouse into a store cooler. In addition to the robbery, the defendant was convicted of three counts of false imprisonment for the cooler incident. He was sentenced on all counts including consecutive counts on the three false imprisonment charges. The Court of Appeal concluded that "each false imprisonment count was punishable as a crime of violence against a separate individual." (Id. at p. 28.)