California, United States of America
The following excerpt is from People v. Villagran, 210 Cal.Rptr.3d 426, 5 Cal.App.5th 880 (Cal. App. 2016):
People v. Mickle (1991) 54 Cal.3d 140, 176, 284 Cal.Rptr. 511, 814 P.2d 290 ["Where committed for a sexually exploitative purpose, [the actual or constructive disrobing of a child by the accused] is presumptively harmful and prohibited by section 288(a)."]; People v. Roberts (1972) 26 Cal.App.3d 385, 387-388, 103 Cal.Rptr. 25 [defendant charged as aider and abettor of violation of 288 need not have physical contact with victim].)
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