People v. Leung

In People v. Leung (1992) 5 Cal.App.4th 482, the three defendants entered a restaurant with weapons and took the restaurant receipts and money from three of the four victims. (Id. at pp. 488-489.) They were convicted of three counts of robbery, one count of attempted robbery and four counts of false imprisonment. (Id. at p. 489.) The trial court imposed consecutive sentences because "they were separate offenses" and "separate victims." (Id. at p. 502.) The Leung court rejected one defendant's argument that they were not separate offenses because they "took place at the same time and place and no single count charged defendant with an offense against more than a single victim." (Ibid.) The Leung court stated, inter alia, that the "culpability of the defendant who victimizes multiple individuals is greater than the culpability of a defendant who victimizes a single individual," and consecutive sentences were justified. (Id. at pp. 504-505)