People v. Gray, 58 Cal. 4th 901

Culver City first installed a red light camera in 1998, publicly announced it, and issued only warning notices for the initial 30 days per Veh. Code § 21455.5(b).
The City later installed additional cameras at other intersections (including one at Washington Blvd. & Helms Ave. in 2006) without new public announcements or 30-day warning periods.
In 2008 a camera at Helms Ave. photographed a vehicle registered to Steven Gray running a red light; Gray was cited under Veh. Code § 21453(a).
Gray moved to dismiss, arguing § 21455.5(b) requires a public announcement and 30-day warning period for each new camera installation; trial and appellate courts rejected that defense and convicted Gray.
The California Supreme Court granted review to decide (1) whether the statute’s “system” language applies to each intersection camera or only the citywide program, and (2) whether failure to comply with the 30‑day warning requirement invalidates later citations (i.e., is jurisdictional).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of “system” in § 21455.5(b): does it apply to each camera/ intersection or only to a citywide program?	The City: “system” refers to the citywide automated enforcement program; requirements apply only at first citywide installation.	Gray: each camera is a separate “system,” so each new installation requires a public announcement and a 30‑day warning period.	The Court: “system” refers to the camera at a particular intersection; § 21455.5(b) requirements apply each time a camera is installed.
Effect of noncompliance with § 21455.5(b)’s 30‑day warning period: does failure to comply bar prosecution or deprive court of jurisdiction?	The People: compliance is not a jurisdictional prerequisite; statute does not prescribe consequences and does not make compliance an element of a § 21453(a) prosecution.	Gray: failure to provide 30 days of warnings prior to issuing citations invalidates citations based on camera evidence (jurisdictional defect).	The Court: the 30‑day warning requirement is not a jurisdictional precondition; persons not within the class protected by the requirement (e.g., violators occurring years later) cannot invoke noncompliance to invalidate prosecutions.

People v. Stanley, 54 Cal.4th 734 (statutory construction starts with text; intent governs)
People v. Canty, 32 Cal.4th 1266 (read words in context of the statutory scheme)
People v. King, 38 Cal.4th 617 (use legislative intent where language ambiguous)
People v. Dillon, 34 Cal.3d 441 (same-word-meaning presumption in statutory schemes)
City of Santa Monica v. Gonzales, 43 Cal.4th 905 (distinguishing directory vs. mandatory requirements; consequences of noncompliance)
People v. McGee, 19 Cal.3d 948 (purpose test for whether procedural requirements confer private benefit)
In re Richard S., 54 Cal.3d 857 (use of “shall” may be directory when administrative)
Bouie v. City of Columbia, 378 U.S. 347 (due process and unforeseeable judicial construction; retroactivity concerns)