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 later entering a room within that structure does not automatically support two burglary convictions. A second burglary is permissible only when the interior room provides a separate, objectively reasonable expectation of protection from intrusion, such as through distinct possession or separate security. Because the store bathroom did not meet that standard, the court reversed the judgment concerning Garcia's dual burglary convictions and remanded for further proceedings. Justice Kruger, joined by Justice Liu, concurred and emphasized that the interior room must function like a separate unit rather than merely provide greater privacy or security than other rooms.