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Name: Statutory Construction
Summary

Appellant, an inmate in a county jail, was convicted of felony vandalism in violation of Penal Code section 594, subdivision (b)(1). The Court of Appeal agreed he was improperly prosecuted under section 594, rather than section 4600, for damaging two safety cells while on suicide watch. His conviction under section 594 was barred by the plain language of section 594 itself. Section 4600 specifically criminalizes the destruction or injury of jail or prison property by inmates, while section 594 applies only “in cases other than those specified by state law.” This limiting clause reflects the Legislature’s intent to exclude from section 594’s scope conduct addressed by other, more specific statutes, such as section 4600’s prohibition against damaging jail property. Reversal was required.