California, United States of America
The following excerpt is from People v. Gary, D071646 (Cal. App. 2018):
Courts have interpreted the term "particularly vulnerability" as follows: " ' "[p]articularly . . . means in a special or unusual degree, to an extent greater than in other cases. Vulnerability means defenseless, unguarded, unprotected, accessible, assailable, one who is susceptible to the defendant's criminal act." [Citation.]' [Citation.] Thus, a crime victim can be deemed particularly vulnerable as an aggravating factor 'for reasons not based solely on age, including the victim's relationship with the defendant and his [or her] abuse of a position of trust.' [Citations.]" (People v. DeHoyos (2013) 57 Cal.4th 79, 154.)
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