In what circumstances will a defendant be found guilty of a violation of section 134 of the California Penal Code for submitting a false receipt?

In People v. Laws (1981) 120 Cal.App.3d 1022, 178 Cal.Rptr. 102 (Laws ), defendant submitted to the court a false receipt showing he had made full restitution to a crime victim and thereby complied with his conditions of probation. ( Id . at pp. 1027-1028, 178 Cal.Rptr. 102.) Defendant had not actually paid the full amount of restitution and had duped the victim into signing the receipt. ( Id . at pp. 1026-1027, 178 Cal.Rptr. 102.) Defendant was prosecuted for a violation of section 134 for submitting the receipt containing false information. ( Laws , at p. 1026, 178 Cal.Rptr. 102.) In arguing on appeal that the evidence was insufficient to support the conviction for section 134, defendant asserted that the receipt was "regular on its face" and therefore did not constitute a false paper within the meaning of section 134. The Laws court rejected that contention and concluded the evidence established that the defendant "knew that the receipt was literally false and

[41 Cal.App.5th 404]