California, United States of America
The following excerpt is from People v. Green, 146 Cal.App.3d 369, 194 Cal.Rptr. 128 (Cal. App. 1983):
Section 451 also substituted the words "inhabited structure" for the term "dwelling house" used in former section 447a. Section 450(d) defines "inhabited" as "currently being used for dwelling purposes, whether occupied or not"; this is the same definition used in the burglary statute, Penal Code section 459. "Structure," defined in section 450, subdivision [146 Cal.App.3d 379] (a), includes "any building." This deliberate and careful choice of language indicates a "manifest legislative intent to provide more stringent punishment for the narrow category of crimes against property which involves the deliberate attempted or actual burning of buildings likely to be inhabited, because of the obvious danger to human life attendant thereon." (People v. Earnest, 53 Cal.App.3d 734, 748, 126 Cal.Rptr. 107.)
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