The Court of Appeal agreed with appellant’s argument that his conviction for arson of forest land (Pen. Code, § 451, subd. (c)) was not supported by substantial evidence, because there was not sufficient evidence that the area burned (a backyard in a residential area) constituted “forest land.” As such, the Court of Appeal ordered the trial court to dismiss his conviction and enhancement and vacate his fourteen year and eight month sentence, noting that appellant could not be retried on remand.