California, United States of America
The following excerpt is from In re Lawrence, C042242. (Cal. App. 2003):
From this record, we cannot say that the court ruled to reduce the charge under section 243.4, subdivision (a) to a charge under section 243.4, subdivision (e). Rather, a reasonable reading of the record suggests that the court deemed the section 243.4, subdivision (a) offense to be a misdemeanor. However, whether designated a felony or a misdemeanor, a violation of section 243.4, subdivision (a) requires proof of contact with the victim's skin. (People v. Elam, supra, 91 Cal.App.4th at pp. 309-310.) There is no evidence of such contact in this record.
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