How have courts treated the issue of lewd and disorderly conduct on appeal?

The sole contention on appeal is that the trial court erred by failing to instruct, sua sponte on the offense of lewd and disorderly conduct (Pen.Code, 647, subd. (a)) as a necessarily included lesser offense to indecent exposure. (Pen.Code, 314, subd. 1.) The trial court has a sua sponte obligation to instruct on any necessarily lesser included offenses. (People v. Sedeno (1974) 10 Cal.3d 703, 715-716, 112 Cal.Rptr. 1, 518 P.2d 913.) The question is whether the commission of the offense of indecent exposure necessarily includes the commission of the offense of lewd and disorderly conduct. (See People v. West (1970) 3 Cal.3d 595, 612, 91 Cal.Rptr. 385, 477 P.2d 409.)