In People v. Gonzalez (2014) 60 Cal.4th 533, the court was confronted with the question of "whether a defendant may, consistently with ... section 954, be convicted of both oral copulation of an unconscious person citation and oral copulation of an intoxicated person citation based on the same act." (Id. at p. 535.) The court began its analysis by observing, "We have repeatedly held that the same act can support multiple charges and multiple convictions. 'Unless one offense is necessarily included in the other citation, multiple convictions can be based upon a single criminal act or an indivisible course of criminal conduct ( 954).' " (Gonzalez, at p. 537.) The court treated the issue as one of statutory interpretation: "The determination whether subdivisions (f) and (i) of section 288a define different offenses or merely describe different ways of committing the same offense properly turns on the Legislature's intent in enacting these provisions, and if the Legislature meant to define only one offense, we may not turn it into two." (Ibid.) Although oral copulation of an unconscious person and oral copulation of an intoxicated person are reflected in subdivisions of a single statute, the court held they are separate offenses. It reasoned, "Section 288a is textually and structurally different from former section 261 (i.e., rape). Subdivision (a) of section 288a defines what conduct constitutes the act of oral copulation. Thereafter, subdivisions (b) through (k) define various ways the act may be criminal. Each subdivision sets forth all the elements of a crime, and each prescribes a specific punishment. Not all of these punishments are the same. That each subdivision of section 288a was drafted to be self-contained supports the view that each describes an independent offense, and therefore section 954 is no impediment to a defendant's conviction under more than one such subdivision for a single act." (Gonzalez, supra, 60 Cal.4th at p. 539.)