California Supreme Court

The People, Plaintiff and Respondent v. Hugo Garcia, Defendant and Appellant

February 25, 201662 Cal. 4th 1116

Summary

The court held that entering a structure with felonious intent and then entering an interior room does not automatically support two burglary convictions. A second burglary is permissible only when the interior space provides a separate, objectively reasonable expectation of protection from intrusion, such as through distinct possession, occupancy, or security; the store bathroom did not meet that standard. The court therefore reversed the judgment concerning the dual burglary convictions and sentence and remanded for further proceedings. Kruger, J., concurring, agreed with the result but emphasized that the decisive inquiry is whether the interior room functions as a separately protected unit rather than merely offering greater privacy than surrounding rooms.