People v. Henry, 28 Cal. App. 5th 786

Angelo Amir Henry was stopped for a traffic violation, gave an acquaintance's name (Ismael Pugh) and signed a promise-to-appear citation using that name; he later admitted he had a suspended license and used a false name to avoid probation/prison consequences.
The Monterey County DA charged Henry with felony false personation (Pen. Code § 529(a)(3)) plus vehicle offenses; a jury convicted him of the felony and a misdemeanor driving-without-license charge.
Henry had prior strike convictions; the felony produced a prison sentence and led the trial court to revoke/terminate probation in two earlier matters.
On appeal Henry argued the felony prosecution violated the Williamson rule because Vehicle Code § 40504(b) specifically makes signing a promise-to-appear with a false or fictitious name a misdemeanor.
The Court of Appeal reviewed whether the Williamson rule applied (i.e., whether the specific Vehicle Code misdemeanor governs conduct commonly encompassed by the general false-personation felony) and whether legislative intent showed the misdemeanor was intended to be exclusive.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Williamson rule precludes felony prosecution under Pen. Code § 529(a)(3) when the conduct is covered by Veh. Code § 40504(b)	The People argued Williamson does not apply because the special statute can be violated in ways (e.g., signing a fictitious name) that would not violate the general false-personation statute, so the general felony remains available	Henry argued that signing a false name on a promise to appear is the type of conduct the Vehicle Code misdemeanor was enacted to punish and therefore prosecution must be under the special misdemeanor statute, not the general felony statute	The court held Williamson applies: signing a false name on a promise to appear commonly results in false personation, and the legislature intended that conduct be prosecuted as a misdemeanor under Veh. Code § 40504(b); felony conviction reversed and remanded for resentencing.

In re Williamson, 43 Cal.2d 651 (Cal. 1954) (establishes rule that a specific statute controls over a general statute covering the same conduct)
People v. Murphy, 52 Cal.4th 81 (Cal. 2011) (clarifies application of Williamson by focusing on whether violation of the special statute will necessarily or commonly result in violation of the general statute)
People v. Ruster, 16 Cal.3d 690 (Cal. 1976) (applies Williamson where special statute commonly encompassed conduct punishable under a more general statute)
People v. Watson, 30 Cal.3d 290 (Cal. 1981) (explains limits of Williamson where general statute contains an element, such as malice, not commonly present in special-statute violations)
People v. Chardon, 77 Cal.App.4th 205 (Cal. Ct. App. 1999) (held Williamson did not apply to these same statutes pre-Murphy; court here concludes Chardon is no longer persuasive)