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Name: People v. Joiner
Case #: F028186
Court: CA Court of Appeal
District 5 DCA
Opinion Date: 11/07/2000
Subsequent History: Petn. rehg. den. 12/4/00; Petn. rev. den. 2/28/01

The false verification of vehicle identification numbers (VIN) by a person authorized to verify such numbers to the Department of Motor Vehicles (DMV) pursuant to Vehicle Code section 675.5 constitutes a violation of Vehicle Code section 10802, as it falls within the prohibition of falsifying VIN numbers. Other conduct designed to prevent the identity of a vehicle that does not include tampering with the VIN is not a violation of section 10802. Moreover, aider and abettor liability for a violation of section 10802 does not attach to conduct committed after the tampering has been completed. Therefore, where Joiner drove the vehicle at issue after the VIN had already been tampered with, there was insufficient evidence to support his conviction for a violation of section 10802. The crime was completed after the VIN number was altered with the specific intent to conceal the identity of the vehicle. Transfer or sale of the vehicle after that time is not within the statute, and therefore aiding and abetting liability did not attach to the codefendant who made the sale of the vehicle.