Tooby's California Post-Conviction Relief for Immigrants
§ 12.21 C. Other Less Common Forms of Diversion
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CAL POST CON " SAFE HAVEN " ARSON " GENERAL INTENT
In re V. V., 51 Cal.4th 1020, 252 P.3d 979 (Jun. 6, 2011) (California convictions for violations of California Penal Codes 451(c), arson of a forest land, and 452(c), recklessly causing a fire, affirmed where minor defendants acts of intentionally igniting and throwing a firecracker amidst dry brush on a hillside, although done without intent to cause a fire or other harm, were sufficient to establish the requisite malice for arson).