California, United States of America
The following excerpt is from In re Corpus, D069374 (Cal. App. 2016):
area of the defendant's home to the front door without challenge and that area was open to common or general use. (Id. at p. 598.) In contrast, in People v. White (1991) 227 Cal.App.3d 886, the court concluded the front yard of a private residence in that case was not a "public place" within the meaning of Penal Code section 647 because it was surrounded by a three-and-a-half-foot high fence with a closed, but unlocked, gate and contained three dogs released by the defendant, all of which circumstances provided challenge to public access. (White, at p. 892.)
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