What is the test for a claim that a defendant failed to pay her share of rent due to the fact that the landlord was her grandmother?

California, United States of America


The following excerpt is from People v. Rhoades, C078140 (Cal. App. 2018):

Defendant argues there was no evidence (or no sufficient evidence) that she failed to pay her share of the rent. However, it does not matter whether defendant paid her share. What matters is that the potential for fraud justifies the regulation, and defendant violated the regulation by concealing that her landlady was her grandmother. There need not be a perfect fit between means and ends. (Heller v. Doe (1993) 509 U.S. 312, 321.) Similarly, it does not matter that fraud can also happen if one rents from a more distant relative or from a friend. As noted, there need not be a perfect fit between means and ends.

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