What is the test for determining whether a defendant obtained a car by knowingly giving an incorrect home address?

California, United States of America


The following excerpt is from People v. Lafond, D066439 (Cal. App. 2015):

Defendant nonetheless contends he did not intentionally give an incorrect home address when he rented the car. Even assuming there is evidence in the record that, if credited, would support this finding, as a court of review our role is to review the record to determine whether substantial evidence supports the finding or findings made by the trier of fact, not to make new or contrary findings based on the evidence. (See People v. Parson, supra, 44 Cal.4th at p. 345.) Because substantial evidence supports the finding of the trial court that defendant obtained the car by knowingly using a false address (see Pen. Code, 484, subd. (c)), we independently conclude the court properly found defendant had no reasonable expectation of privacy to challenge the subsequent search of the car.

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