Tag Archives: CC 1151


Does Pandering Require Procurement of Services for a Person Other Than the Defendant?
February 27th, 2020

There is a split of authority on whether pandering, per PC 266i(a)(2) requires that services be procured for a person other than the defendant. (People v. Dixon (2011) 191 Cal.App.4th 1154, 1159- 1160 [third person required]; People v. Jacobo (2019) 37 Cal.App.5th 32, 47 [no third person required].)   Jacobo rejected Dixon as follows:   […]


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Pandering: Clarification of Elements
October 2nd, 2015

In February, 2012, the CC Committee revised CC 1151 explaining that it does not matter whether the “prostitute” was a prostitute already or whether he or she was an undercover police officer.   In People v. Zambia (2011) 51 Cal. 4th 965, Supreme Court Justice, and former committee chair, Carol A. Corrigan answered the long […]


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