What is the reasonable reliance defense when applying to section 476a (passing worthless checks)?

9 Numerous courts have passed on the issue of a reasonable reliance defense when applying Penal Code section 476a (passing worthless checks). In People v. Rubin (1963) 223 Cal.App.2d 825, 835, 36 Cal.Rptr. 167, the court noted that "[t]he rule of law upon which the defendant relies requires that there be a 'reasonable expectation of funds' as the source for payment of the check upon its presentation. ... 'The expectation of the defendant must, however, be more than mere hope. The circumstances must be such as to justify a reasonably certain belief that funds will be available.' " Here, petitioner had no grounds to be reasonably certain that the bank would honor his check.