People v. Dunbar, 146 Cal. Rptr. 3d 673

Dunbar, office manager and controller at Fields Pianos (2001–2005), deposited customers’ checks into his own account.
Auditors later found he shorted Fields by over $6.8 million between 2003 and 2005.
To cover up the scheme, Dunbar deposited forged checks and altered deposit slips to show full payment to Fields.
Defendant was charged with 48 forgery counts under Penal Code sections 470(d) and 471; 24 counts under 471 alleged false entries in Fields’s private records.
The trial court dismissed the 24 counts under 471, prompting People’s appeal.
The issue presented is whether Penal Code section 471 criminalizes forgery of private books of records.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does 471 apply to private records?	People: 471 applies to any book of records, public or private.	Dunbar: 471 limits to public records.	471 covers private records; Statute unambiguously broad.
Is the term 'any book of records' ambiguous and subject to extrinsic interpretation?	People: language is plain and unambiguous.	Dunbar: extrinsic sources suggest ambiguity and limitation to public records.	Language is unambiguous; no extrinsic interpretation adopted.

Voices of the Wetlands v. State Water Resources Control Bd., 52 Cal.4th 499 (Cal. 2011) (plain language controls if unambiguous)
People v. King, 38 Cal.4th 617 (Cal. 2006) (interpretation of statutory language)
Hartford Fire Ins. Co. v. Macri, 4 Cal.4th 318 (Cal. 1992) (against creating ambiguity where none exists)
Monette-Shaw v. San Francisco Bd. of Supervisors, 139 Cal.App.4th 1210 (Cal. App. 2006) (extrinsic sources do not alter clear statutory text)
Pacific Gas & Electric Co. v. Public Utilities Com., 85 Cal.App.4th 86 (Cal. App. 2000) (limits of extrinsic material in statutory interpretation)
Delaney v. Superior Court, 50 Cal.3d 785 (Cal. 1990) (interpretation of the word 'any' as broad and unlimited)