Can a motor vehicle violation be reduced to a petty theft under section 490.2 of the California Vehicle Code?

Defendant observes that Proposition 47 provides for a "liberal[]" construction to effectuate its purposes, which include "[r]equir[ing] misdemeanors instead of felonies for nonserious, nonviolent crimes like petty theft and drug possession." (Guide, supra, text of Prop. 47, 18, 3, pp. 74, 70.) However, in view of the text of section 490.2 and Vehicle Code section 10851(a), and the ballot materials for Proposition 47, we do not believe that a liberal construction of Proposition 47 can support the conclusion that felony violations of Vehicle Code section 10851(a) may be redesignated as misdemeanor petty thefts under section 490.2. (See Nickelsberg v. Workers' Comp. Appeals Bd. (1991) 54 Cal.3d 288, 298 ["the rule of liberal construction . . . should not be used to defeat the overall statutory framework and fundamental rules of statutory construction"].)