In what circumstances will a court change the meaning of the word "firearm" to include handgun?

California, United States of America


The following excerpt is from People v. Lal, C080696 (Cal. App. 2017):

In People v. Runnion (1994) 30 Cal.App.4th 852, the defendant was charged with robbery, with a personal firearm use allegation. (Id. at p. 854.) The trial court omitted the portion of the instruction defining "firearm"; instead, it simply instructed that, " '[t]he word "firearm" includes handgun.' " (Id. at p. 855.) On appeal, the defendant contended this instruction relieved the state of its burden of proving the object the defendant used

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