Law School Case Brief
People v. Woods - 65 Cal. App. 4th 345
Courts have explained that the term "inhabited dwelling house" means a structure where people ordinarily live and which is currently being used for dwelling purposes. The burglary statute, Cal. Penal Code § 459, defines "inhabited" as currently being used for dwelling purposes, whether occupied or not. The proper focus is whether the attached structure is an integral part of a dwelling, that is, functionally interconnected with and immediately contiguous to other portions of the house.
Police officers responded to a report of a burglary in progress at an apartment complex. The officers found defendant Christopher Ray Woods and a female companion inside a laundry facility within the complex. One of the washing machines had been pulled from the wall and its coin box had been broken. Fresh pry marks were visible on the door to the laundry room. The apartment manager told police he had locked the laundry room an hour before and at that time nothing in the room had been disturbed. The manager further reported that neither Woods nor his companion lived in the complex. After trial in California state court, Woods was convicted of first degree burglary. On appeal, Woods argued the evidence did not support a first degree burglary conviction because a "commercial laundry facility" within the common area of an apartment complex did not constitute an inhabited dwelling house. He further argued that reversal was required because the information under which he was charged failed to properly identify the victim of the burglary.
Was Woods properly convicted of first-degree burglary?
The appellate court affirmed the trial court's judgment. The court held that the evidence was sufficient to support a finding, under the reasonable expectation test, that the common area laundry room was an area where tenants would expect protection from unauthorized intrusions, and thus it qualified as an inhabited dwelling. The laundry room was under the same roof and immediately contiguous to occupied apartments above and below, was an integral part of the complex, and was used by tenants to do their laundry—a household chore. It was not necessary that the laundry room be an integral part of any of the individual dwelling units in the complex. The laundry facility met the reasonable expectation of protection test, since the evidence established the room was usually kept locked so that only tenants were permitted access to it by way of their own keys, and would thus expect protection from unauthorized intrusions. As to Woods' challenge to the information, the court ruled that Woods waived any objection to the sufficiency of the information by failing to demur on the ground the charging allegation was not sufficiently definite. Regardless, the challenge failed because pleading and proof of a burglary victim's identity was not necessary.
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