Is there a distinction between an attached garage with an outside door for purposes of determining the degree of burglary?

California, United States of America


The following excerpt is from 70 Cal.App.4th 1287C, Edwardo V., In re, 70 Cal.App.4th 591, 82 Cal.Rptr.2d 765 (Cal. App. 1999):

People v. Ingram (1995) 40 Cal.App.4th 1397, 48 Cal.Rptr.2d 256 confirmed "[t]here is no meaningful distinction between an attached garage with an outside door and an attached garage with an inside door for purposes of deciding the degree of burglary. The close physical proximity of an attached structure is precisely what increases the potential for confrontation and threatens the safety of residents. This potential is no less when access to the garage is from outside rather than from inside the house. The proper focus is whether the attached structure is an integral part of a dwelling, that is, functionally interconnected with and immediately contiguous to other portions of the

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