How have the courts interpreted the language of Section 881(a)(6) of the California Criminal Code?

The error was plain. Although it is hard to fault the district court for giving an instruction that tracked the language of 881(a)(6), the statute cannot mean what it literally appears to say. See United States v. Paul , 37 F.3d 496, 497 (9th Cir. 1994) (reversing for plain error even though the district court gave the Ninth Circuit model jury instructions). For hundreds of years, the common law from which we derive the core principles of our criminal law has held that mere intent without some act to carry out the intent is not a sufficient basis for punishment. That principle is reflected in the way in which we have long approached inchoate crimes such as attempt, conspiracy, and solicitation. It has been also captured in various ways in our Eighth Amendment jurisprudence, which prohibits punishing someone for their desires divorced from any action in furtherance of those desires.