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Name: People v. Sparks
Case #: S098290
Court: CA Supreme Court
District CalSup
Opinion Date: 06/06/2002
Subsequent History: None

The California Supreme Court granted review in this case to address the conflict in Court of Appeal decisions concerning whether a defendant’s entry into a bedroom within a single-family house with the requisite intent can support a burglary conviction if that intent was formed only after the defendant’s entry into the house. (Appellant was selling magazines and entered the home with consent in order to get a glass of water. He followed the victim into her bedroom and raped her. The prosecution argued that appellant was guilty of burglary if he formed the intent to rape prior to entering the victim’s bedroom. The jury was instructed that burglary was an entry into a building or any room within a building with the requisite intent.) The Court here concluded that the trial court did not err in defining burglary to include entry into the victim’s bedroom with the specific intent to commit rape. The victim could reasonably expect significant additional privacy and security when she retreated into her own bedroom.