In California, you can find yourself in serious legal trouble simply by entering a place without permission — especially if authorities believe you intended to commit a theft or another felony once inside.
“Breaking and entering” is a common phrase, but in California it refers to the crime of burglary under Penal Code 459. In simple terms, you commit burglary by entering someone else’s property with the intent to commit theft or any felony inside.
There is no separate law called “breaking and entering” – even entering through an unlocked door can be charged as burglary if you intended to steal or commit a crime once inside. Burglary charges are serious and can lead to heavy penalties, including prison time and a strike on your record.
- Understanding California burglary law (Penal Code 459)
- First-degree vs. second-degree burglary
- Common scenarios charged as burglary in California
- Prosecutorial practices in Southern California (Los Angeles & Ventura)
- Diversion, sentencing trends, and plea bargaining options
- Defenses against burglary charges
Understanding California burglary law (Penal Code 459)
Under California Penal Code §459, burglary is defined as entering any structure (house, apartment, store, garage, etc.) or a locked vehicle with the intent to commit theft or any felony once inside.
Two key elements make up a burglary:
1. Entry of a structure or locked vehicle
You enter a building, room, or vehicle that you have no lawful right to enter. Importantly, this entry does not require breaking a window or picking a lock – no force is necessary.
Simply crossing the threshold, even through an open door or window, counts as entry. In fact, California law says entry can be as minimal as sticking your hand or an object inside a building’s outer boundary. For example, reaching through a window with a tool or walking through an unlocked door qualifies as entering for burglary purposes. (The only exception is for car burglary – the vehicle must be locked for it to count as burglary of a vehicle.)
2. Intent to commit theft or a felony inside
At the moment you enter, you must have the specific intent to steal something or commit a felony crime inside. This intent element is what separates burglary from merely trespassing. If you enter a building with no criminal intent, it’s not burglary – even if you wandered somewhere you shouldn’t be, that scenario might be a trespass instead.
Prosecutors must prove you already intended to commit a theft or other felony when you stepped inside. It is not necessary that you actually carry out the crime; the law focuses on what you planned to do at entry. In other words, burglary is complete the moment the unlawful entry with criminal intent occurs, even if nothing is ultimately stolen. Conversely, if you only decided to commit a crime after you were inside, then the burglary charge doesn’t hold. (You could still face charges for any crime committed inside, but it would not be burglary without that pre-existing intent.)
California’s burglary law applies broadly to many types of “structures.” A structure isn’t just a house or store – it can include things like garages, storage units, fenced commercial yards, and more. Even entering certain areas not open to the public (like the back room of a store) can count. Notably, entering someone’s inhabited dwelling (their home) is treated more severely under the law than entering other structures. California divides burglary into two degrees based on this distinction, as explained next.
First-degree vs. second-degree burglary
All burglaries in California fall into either first-degree or second-degree, which carry very different consequences. It’s crucial to understand the difference:
First-degree burglary (residential burglary)
First-degree burglary means a burglary of an inhabited dwelling – basically, someone’s home or any place currently used as a residence. Breaking into a house, apartment, condo, mobile home, or even a boat or RV that serves as living quarters would be first-degree burglary. The law considers residential burglary especially serious because it invades the privacy and safety of where people live. It doesn’t matter whether anyone was home at the time; as long as the place is ordinarily used as sleeping or living space, it counts as an inhabited dwelling.
Penalties: First-degree (residential) burglary is always a felony in California. A conviction carries state prison sentences of two, four, or six years. It also counts as a “strike” offense under California’s Three Strikes Law. This means if you are convicted, you’ll have a strike on your record – any future felony conviction could result in double the prison time, and a third strike can mean 25-years-to-life. Because it’s a strike, if someone was injured or present during the burglary, sentencing becomes even harsher (a residential burglary with occupants present is considered a violent felony, requiring serving at least 85% of the sentence). In short, judges and prosecutors treat first-degree burglary very harshly, often seeking prison time, because it violates the sanctity of someone’s home.
Example: Suppose a man breaks into a house at night by prying open a window, intending to steal jewelry. This is a classic first-degree burglary scenario – an occupied residence was entered by force for theft. Even if the family was away on vacation and no one was home, it’s still first-degree residential burglary. Because it’s a home, he will face felony charges and potentially several years in state prison if convicted.
Second-degree burglary (commercial burglary)
Second-degree burglary refers to all other burglaries that are not of inhabited homes. This usually means burglary of commercial properties like stores, businesses, warehouses, or of structures such as garages, storage units, or any building not used as a residence. It also includes auto burglary (breaking into a locked vehicle to steal something). Second-degree is sometimes called commercial burglary since it often involves places of business, but it can be any non-residential structure.
Penalties
Second-degree burglary is a “wobbler”, which means it can be charged either as a felony or as a misdemeanor, depending on the circumstances and your background.
Prosecutors have discretion here. If charged as a misdemeanor, the potential penalty is up to 1 year in county jail and a $1,000 fine (along with possible probation). If charged as a felony, second-degree burglary can lead to 16 months, 2 years, or 3 years of incarceration (often in county jail under realignment) and fines up to $10,000.
Because second-degree burglaries vary widely in seriousness, a first-time offender who stole something minor might get a misdemeanor and probation, whereas someone with a record who committed a large break-in could face a felony.
Unlike first-degree, a second-degree burglary can potentially be reduced to a misdemeanor (or even dismissed through negotiations), especially if the value of what was taken is low. In fact, after recent legal changes (Proposition 47), entering a commercial establishment during business hours to steal items worth $950 or less is usually treated as the separate crime of shoplifting (a misdemeanor), not burglary. But planned thefts above that amount – or any break-in after hours – will be prosecuted as burglary.
Example: A teenager smashes a department store window after closing to grab electronics. This is second-degree burglary of a commercial building. If caught, he could be charged with a felony because it was a forced entry and involved valuable merchandise. On the other hand, consider someone who walks into an open retail store during the day with an intent to shoplift $500 worth of clothes. Technically, they entered with intent to steal, which fits the definition of burglary.
However, because the value is under $950 and it was an open business, today this scenario would likely be charged as misdemeanor shoplifting instead of burglary. If the same person planned to steal a much larger amount (say $2,000 worth of goods) or entered a closed store after hours, the prosecutor would treat it as second-degree burglary, potentially a felony, since it involves a bigger, premeditated theft.
Common scenarios charged as burglary in California
Burglary charges can arise from a wide range of real-world situations. It’s not always the stereotypical masked intruder at midnight – many everyday scenarios can lead to a Penal Code 459 charge. Here are some common scenarios in California that end up charged as burglary:
Mistaken entry or wrong address
A person enters the wrong house or apartment by accident. For example, a house guest might return to what they think is their friend’s home, only to discover they walked into the neighbor’s similar-looking house. Or an intoxicated individual wanders into the wrong apartment late at night. Even without criminal intent, these situations can lead to an arrest for burglary if a startled homeowner calls the police. Often these cases are misunderstandings – the person had no intent to commit a crime – but police may initially treat it as a burglary until intent (or lack thereof) is sorted out.
Entering through an unlocked door or open garage
Not all “break-ins” involve breaking anything. Many burglaries happen when someone notices an easy opportunity – say, an open garage door, an unlocked front door, or a gate left ajar – and walks in to steal property.
For instance, a thief might see a garage door accidentally left open in the neighborhood and sneak in to take a bike or tools. Or someone might try various car door handles, find one car unlocked, and enter to steal a wallet. California law still calls this burglary because there was an entry with intent to steal, even though no force was used to get inside.
Use of tools or forced entry
This is the classic form of breaking and entering – using burglary tools or force to gain entry. Examples include prying open a door with a crowbar, picking a lock, breaking a window, or using a stolen key or credit card to jimmy a lock. If an individual carries lock picks, crowbars, or other break-in tools and is caught entering a building, it’s strong evidence of intent.
A typical scenario would be burglars using a crowbar to pop open the back door of a closed convenience store at night to raid the cash register. Even attempting to pry your way in (and perhaps getting scared off by an alarm before taking anything) is still charged as burglary because the intent to commit theft was present at entry.
Entering a business with a theft plan (commercial burglary)
Many people are surprised that you can be charged with burglary for what looks like shoplifting. If you enter a retail store specifically intending to steal merchandise, it can be charged as burglary. The distinguishing factor is the intent beforehand. For example, two individuals might walk into a big-box store with empty bags and a scheme to fill them with high-value items and run out. If they plan this out in advance, prosecutors can charge it as commercial burglary.
As mentioned, California created a separate “shoplifting” misdemeanor for minor thefts during store hours (to give first-time offenders lighter consequences), but if the theft planned is large or if the person has disqualifying priors, it becomes burglary. Another scenario: entering a supermarket after hours (when it’s closed) by slipping through an unlocked loading door, intending to steal beer and cigarettes – that is clearly burglary. In short, any entry into a business with the intent to steal or commit felony fraud (like using stolen credit cards inside) can lead to burglary charges, even if the business is open to the public at the time.
Often the line between a trespass, a shoplifting, and a burglary comes down to what prosecutors believe you were planning to do.
Even a seemingly small act – like stepping into an open garage or walking out of a store with unpaid goods – can be elevated to burglary if there is evidence it was intentional and pre-planned. That’s why context and intent are so important in these cases.
Prosecutorial practices in Southern California (Los Angeles & Ventura)
Burglary cases are taken very seriously by prosecutors in Southern California, especially in Los Angeles County and Ventura County. These jurisdictions deal with many burglary incidents, ranging from home break-ins in residential neighborhoods to organized retail theft rings. While the law is the same statewide, how charges are filed and handled can vary based on local policies and the specifics of the case.
In both LA and Ventura, if the facts support it, prosecutors will typically charge the highest degree of burglary possible. For a break-in at an inhabited home, the District Attorney will almost always file it as first-degree residential burglary (a felony strike) given the strong protections for homes. Prosecutors and judges view someone’s home as almost sacred; as a result, home burglaries often prompt aggressive prosecution and a push for prison time. It’s common to see multiple charges if more than one home was hit – each counts as a separate strike. Ventura County prosecutors, serving a smaller community, are known to be very tough on residential burglars to deter crimes that threaten homeowners’ peace of mind. Los Angeles County, with a much larger population and recent increases in property crimes, also pursues residential burglary vigorously – though policies can shift with different D.A. administrations, the baseline is that a person’s house being invaded is a high-priority crime.
For commercial or second-degree burglaries, Southern California prosecutors will weigh the circumstances before deciding on felony vs. misdemeanor. Factors include the value of items stolen, whether the incident involved breaking in after hours (which looks more like a planned crime), and the defendant’s criminal history. In Los Angeles, for instance, if someone with no prior record is caught shoplifting high-end goods by stuffing them in a bag (planned theft but without forced entry), the DA might charge a misdemeanor under the shoplifting law or a misdemeanor burglary, especially under policies aiming to reserve felonies for more serious cases.
Ventura County may be somewhat less inclined to reduce to a misdemeanor if the facts show clear intent and planning, but they also consider first-time offender status. Both counties’ prosecutors often discuss internally whether a case can be handled as a lower offense (like petty theft or trespass) if the evidence of intent is borderline. However, if there was any use of tools, forced entry, or a high-value loss, they are likely to charge felony burglary to leverage the heavier potential sentence.
Proving intent is a critical part of the prosecution’s job in a burglary case, and Southern California prosecutors have developed strategies to do so. They will assemble circumstantial evidence to show you planned a crime upon entry. This can include the fact that you brought burglary tools (for example, carrying pry tools or a glass cutter suggests you didn’t enter innocently), possession of stolen property on you, or your actions caught on camera (like scouting a location or entering a staff-only area of a store).
Sometimes your own statements or admissions can be used – it’s not uncommon for police to obtain a confession or incriminating statements which prosecutors will use to establish what you intended. Even absence of a normal reason to be at the location can be argued as evidence (“He had no legitimate business being in that closed warehouse at midnight”). In Los Angeles, where technology is often used in investigations, prosecutors may pull video doorbell footage, surveillance videos, or even use cell phone data to place you at the scene and infer your movements.
In Ventura County, which has a close-knit law enforcement community, prosecutors often work closely with sheriffs and local police to gather community tips or prior reports of someone casing houses. All of these efforts go toward proving the mindset you had when you entered – a necessary step to secure a burglary conviction.
When it comes to plea deals, Los Angeles and Ventura prosecutors will consider them on a case-by-case basis. Plea bargaining is common in burglary cases, but the willingness to offer a lenient deal depends on the strength of the evidence and the severity of the offense. For instance, in a clear-cut residential burglary with strong evidence (fingerprints, video, stolen items found with the suspect), prosecutors may be less inclined to negotiate anything less than a felony because they feel confident taking the case to trial.
In contrast, if the evidence of intent is a bit weak (maybe you were found in a building but it’s arguable what you were doing there), a prosecutor might offer a reduced charge to avoid the uncertainty of trial. In both counties, first-time offenders or youthful offenders have a better chance at a favorable plea deal. It’s not unusual for a burglary charge in such cases to be reduced to a lesser offense like trespassing (Penal Code 602) or unauthorized entry (a misdemeanor) as part of a plea bargain. For example, Los Angeles prosecutors might agree to a misdemeanor trespass plea for someone who walked into a garage and grabbed a low-value item, rather than pursue a felony burglary conviction – especially if the item was returned and no one was hurt.
Ventura prosecutors, though tough, might also offer a reduction if convinced the incident was isolated and the defendant is genuinely remorseful. Bottom line: Prosecutors in Southern California will push for serious consequences for burglary, but with skilled negotiation it’s often possible to reach a compromise – particularly on second-degree cases – that avoids the most severe penalties. Knowing the tendencies of the local DA’s office is something a seasoned defense attorney like Robert M. Helfend uses to strategize the best outcome.
Diversion, sentencing trends, and plea bargaining options
Being charged with burglary doesn’t always mean a straight path to prison. In California today, there is a greater emphasis on rehabilitation and smart sentencing, especially for non-violent property crimes. Depending on the case, there may be alternatives like diversion programs or reduced charges that can dramatically soften the impact on your life.
Diversion programs and alternative sentencing
In Southern California, courts and prosecutors have discretion to offer diversion in certain cases – typically for first-time offenders and non-violent crimes.
Diversion means you participate in rehabilitative programs (such as theft education classes, counseling, community service, or other court-monitored programs) and if you successfully complete the program, the charge can be dismissed, leaving you without a conviction. While burglary is a felony-level offense, a second-degree burglary that didn’t involve violence or a victim confrontation might be considered for a diversion program, especially if the prosecutor is convinced this was an aberration and you’re unlikely to reoffend.
For example, Los Angeles County has shown interest in alternatives to incarceration for lower-level offenders; a young adult who committed a commercial burglary as a prank or under peer pressure might be routed into a program that includes community service and restitution instead of jail. Ventura County also has specialty courts and programs (such as mental health diversion or veterans court) that, if the circumstances fit (like mental health issues contributing to the offense), could allow a burglary defendant to get treatment and avoid a conviction.
Additionally, California’s realignment laws (AB 109) and other reforms encourage judges to consider options like house arrest (electronic monitoring) or extensive probation instead of jail for non-violent property crimes. It’s not uncommon now for a person convicted of a second-degree burglary to serve little to no actual jail time – they might receive probation with conditions like community service, restitution to the victim, and staying away from the location involved.
Sentencing trends in both Ventura and Los Angeles show an openness to these alternatives, as the state tries to reduce overcrowding and focus prison space on violent offenders. However, note that for first-degree residential burglary (being a serious strike offense), diversion is generally not available and judges are more inclined toward incarceration or at least a felony conviction with formal probation. Each case is unique, but the trend is that non-violent burglary offenders have more paths than ever to avoid lengthy jail terms, provided they take responsibility and have strong advocacy.
Plea bargaining and charge reductions
One of the most important roles of a defense attorney is negotiating an acceptable plea deal when appropriate.
In burglary cases, a common strategy is to negotiate the charge down to a lesser offense to avoid the harsh consequences of a burglary conviction.
For example, a felony burglary charge might be negotiated down to a misdemeanor (either burglary as a misdemeanor, if it’s second-degree and eligible, or a different misdemeanor like petty theft or trespass). This can make a huge difference – turning a potential prison sentence into at most a year in county jail (often served via work release or not at all if probation is granted). Another tactic is to plead to “attempted burglary.”
Under California law, an attempted crime carries roughly half the potential sentence of a completed crime. If the evidence is borderline on whether a full entry occurred or whether you really took something, a prosecutor might accept an attempted burglary plea. That could change a mandatory felony into a wobbler or reduce a strike offense to a non-strike (since attempted residential burglary might not count as a strike in some cases). Charge bargaining is also common – sometimes the DA will drop the burglary charge if you agree to plead to something else related, which they can more easily prove.
For instance, if you were found in a store after hours but they aren’t certain you intended to steal, they might offer a plea to trespassing or vandalism (if something was broken) instead of risking a trial on burglary. In one real example, a client in Los Angeles facing commercial burglary for entering a closed store to take money ended up with a deal to plead to receiving stolen property – avoiding the “burglary” label altogether – because his attorney showed weaknesses in the intent evidence. In Ventura County, where prosecutors can be traditional, they may insist on a burglary plea but agree to a low term and probation.
A skilled negotiator like Robert M. Helfend, who knows the local prosecutor’s usual practices, can often secure an agreement that involves no prison time – perhaps probation with a suspended sentence – in exchange for a guilty plea, especially if you have no prior felonies. Sentencing trends in recent years also show judges approving creative plea agreements: for example, pleas held in abeyance (not entered if you complete certain steps), or reductions after a period of good behavior. The key point is that a burglary charge is often negotiable.
With the right approach, it may be possible to reduce a felony to a misdemeanor, avoid a strike on your record, or even get into a program that results in no conviction at all. Each case’s outcome will depend on its facts and the persuasiveness of your defense presentation.
Defenses against burglary charges
Facing a burglary charge can be frightening, but remember that the burden is on the prosecution to prove every element of the crime beyond a reasonable doubt. An effective defense will look for ways to poke holes in those elements – especially the “entry” and “intent” parts. Over his decades of practice, Robert M. Helfend has successfully defended clients by asserting various defenses tailored to their situation.
Some common defenses against burglary charges include:
Lack of intent
Perhaps the strongest defense in many burglary cases is that you did not actually intend to commit a crime inside when you entered. Recall that intent at the moment of entry is required for a burglary conviction. If your attorney can show that you entered for some innocent or different purpose (or even by mistake) and only later something was stolen (or nothing was stolen at all), then the burglary charge doesn’t hold.
For example, maybe you went into a building thinking you had permission, or you were curious and wandered in without any plan to steal – and you took nothing. Or you might have entered intending to retrieve your own property, not to steal someone else’s belongings. All of these scenarios indicate no criminal intent. Without intent, you might be guilty of unlawful entry or trespass at most, but not burglary.
Demonstrating lack of intent often involves scrutinizing the prosecution’s evidence (do they have texts or tools showing a plan? or are they assuming intent from circumstances?). Your lawyer can raise a reasonable doubt by highlighting innocent explanations for your presence. If the jury isn’t convinced you planned a theft or felony, they must acquit on the burglary charge.
Mistaken identity or false accusation
Misidentification is another potent defense – it might not have been you who committed the burglary at all.
In many break-ins, especially nighttime incidents, witnesses may only get a fleeting glimpse of a suspect. Cross-racial identifications, poor lighting, stress, or even intentional false accusations (someone blaming you to cover for themselves) can lead to the wrong person being charged. If you have an alibi (evidence you were somewhere else at the time) or there’s reason to believe the eyewitness got it wrong, your attorney will bring that forward. Surveillance footage might show a different person, or maybe fingerprints at the scene don’t match yours.
In one Ventura case, for example, a homeowner assumed a neighbor’s teenage son was the one who entered his garage, but phone GPS records later showed that teen was miles away at the time – proving it was a case of mistaken identity. Robert M. Helfend and other defense lawyers often employ private investigators to double-check the prosecution’s identification evidence, interview witnesses, and find inconsistencies.
Establishing that you are not the person who committed the crime is a complete defense. If successful, it results in full exoneration.
Legal right or permission to enter (mistake of fact)
This defense admits that you did enter the property but argues that you had a legal right, permission, or a good-faith belief that you could be there or take the item in question.
Sometimes called a “claim of right” or mistake of fact defense, it negates the wrongful intent. For instance, imagine you entered a storage shed to retrieve a lawnmower that you genuinely believed you had permission from the owner to borrow – that’s not burglary because you weren’t intending to steal; you thought it was effectively yours to use.
Similarly, someone might enter a dwelling believing it was their friend’s home or that they were invited, only to find out later they had the wrong address. If you honestly thought you had the owner’s consent to enter (or to take a certain item), then you did not have the intent to commit theft; you thought you were acting lawfully. Another example: taking back an item you sincerely (even if mistakenly) believed belonged to you. These situations can be defenses because they show a lack of criminal intent. It will help if there is evidence backing up your belief – maybe text messages that gave you permission, a spare key you were given, or prior behavior (e.g., you had gone to that property before without issue). While this defense won’t apply if it’s a made-up excuse, genuine misunderstandings do happen and the law recognizes that an honest mistake can prevent a crime from being a crime.
Your attorney can present any evidence of permission or mistake to convince prosecutors (or a jury) that this was not a willful burglary, but rather a miscommunication or misunderstanding.
Insufficient evidence / lack of proof
Sometimes the best defense is simply that the prosecution cannot prove its case.
Maybe there’s no solid evidence placing you inside the premises, or the evidence they have is purely circumstantial and can’t tie you to the crime beyond a reasonable doubt. For example, perhaps the only evidence is a footprint or a tool left behind that could belong to anyone, and nothing directly links it to you.
Or a witness thinks they saw someone in a hoodie, but they’re not certain and there’s no forensic evidence. In such cases, your defense will emphasize the gaps in the prosecution’s proof. Remember, you don’t have to prove you’re innocent – the state has to prove you’re guilty. If your lawyer can show the judge or jury that the evidence is flimsy, inconsistent, or missing key links (like no proof you ever entered the building), you should not be convicted.
We often file motions to suppress illegally obtained evidence or exclude unreliable witness IDs, further weakening the prosecution’s case. In many Ventura and LA courtrooms, Robert M. Helfend has secured dismissals or not-guilty verdicts simply by holding the prosecution to its burden and showing that the evidence they presented was insufficient to convict.
Police misconduct or constitutional violations
While less common, there are cases where the defense can argue that law enforcement violated the defendant’s rights in the course of investigation or arrest, which can lead to evidence being thrown out. For instance, if the police searched your home or car without a warrant or valid exception and found stolen items, those items might be excluded from evidence due to an illegal search (Fourth Amendment violation).
Or if you were coerced into confessing (maybe the police pressured you for hours or made promises), that confession can be deemed involuntary and unusable in court. If crucial evidence is tossed out, the prosecution may be left without enough to continue. Additionally, any overt misconduct like officers planting evidence or falsifying reports – while rare – would completely undermine the case.
An experienced attorney will investigate the conduct of the police to ensure your rights were respected. If not, this defense angle can result in charges being reduced or dismissed.
Robert M. Helfend will personally review all the evidence, listen to your side of the story, and determine the strongest defense approach. In many situations, simply raising a strong defense can push prosecutors to reconsider the charges or offer a much better deal. And if your case goes to trial, a well-prepared defense can convince jurors to have reasonable doubts about the prosecution’s version of events.
When you’re up against a serious charge like burglary, you need more than just the textbook law on your side – you need an advocate with the experience, local knowledge, and tenacity to secure the best possible outcome. Robert M. Helfend is a veteran criminal defense lawyer based in Ventura with over 40 years of experience in Southern California courts, including Los Angeles and Ventura County.
He has defended thousands of clients since starting practice in 1984, and burglary cases are a regular part of his caseload. Robert’s long career means he knows how local prosecutors operate and what strategies can persuade them to reduce or drop charges. He has a deep understanding of investigatory techniques, allowing him to find weaknesses in the prosecution’s case – whether it’s a flawed eyewitness ID or a lack of proof about intent. Moreover, Robert M. Helfend has built a strong reputation in the legal community, recognized by organizations like Super Lawyers and National Trial Lawyers, which reflects his dedication to client success. He personally handles each case and gives clients the honest, straightforward guidance they need during a frightening time.
If you’re facing a burglary (or “breaking and entering”) charge in Los Angeles, Ventura, or anywhere in Southern California, don’t wait to get legal help. The sooner a skilled attorney gets involved, the better your chances of a favorable resolution – be it a dismissal, a not-guilty verdict, or a beneficial plea agreement that keeps your record as clean as possible.
With Robert M. Helfend, you get a Ventura-based defense attorney who combines big-city trial experience with personalized attention. He will fight aggressively to protect your rights, challenge the prosecution’s evidence, and advocate for minimal penalties or alternatives like diversion when appropriate.
For a free, confidential consultation about your case, call 805-273-5611 today.
Published February 20, 2018. Updated June 15, 2025.
References
- California Penal Code § 459. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=459.&lawCode=PEN
- California Penal Code § 461. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PEN§ionNum=461
- 18 U.S. Code § 2118. https://www.law.cornell.edu/uscode/text/18/2118