Does the term "unlawful purpose" in section 530.5, subdivision (a) of the California Criminal Code, require a trial court to define it?

455.) The statutory language of section 530.5, subdivision (a), has been held to be sufficiently clear, not requiring an intent to defraud as a prerequisite for a conviction under that portion of section 530.5. (People v. Hagedorn (2005) 127 Cal.App.4th 734, 748 [holding that the jury was properly instructed on the elements of the offense charged using CALCRIM No. 2040].)

In dicta, the reviewing court in People v. Hagedorn, supra, observed that, standing alone, the phrase "'uses . . . for any unlawful purpose'" might be considered unconstitutionally vague under particular circumstances, because persons of common intelligence might have to guess at its meaning and could differ as to its application." (People v. Hagedorn, supra, 127 Cal.App.4th at p. 746.) However, the court went on to state that "the statute goes on to define 'uses . . . for any unlawful purpose' as including the obtaining, or attempted obtaining, of 'credit, goods, services, or medical information in the name of [an]other person without the consent of that person . . . .'" The court did not hold that term "unlawful purpose" was ambiguous, requiring special instructions, and its holding does not support defendant's assertion that a trial court is required, sua sponte, to define the term "unlawful purpose." In our view, the term "unlawful purpose" is a term commonly understood by those familiar with the English language and is not used in a technical sense peculiar to the law.