Sufficient evidence supported the defendants conviction for violating Penal Code section 290, subdivision (f)(1), where the evidence showed that he had left his previous address without notifying the local police that he was no longer staying at that address, and that he had failed to provide any information regarding his whereabouts for fourteen months. Defendant argued on appeal that subdivision (f)(1) imposed no duty on him to notify police that he had left his prior address, but only to inform police when he had acquired a new address. The court rejected defendants interpretation of the statute, and likewise rejected his argument that the terms “location” and “is located” in the statute were unconstitutionally vague, declining to extend the holding of People v. North (2003) 112 Cal.App.4th 621 to the facts presented here. Finally, the court found that the trial courts error to instruct on the “actual notice” requirement of section 290 was harmless, given the overwhelming and uncontroverted evidence that defendant was aware of the provisions of that section.
Case Summaries