People v. Kim, 193 Cal. App. 4th 836

Defendant Shiseop Kim was charged with felony battery causing serious bodily injury, kidnapping, and attempted dissuasion of a witness; he pled no contest to the battery count and admitted a personal infliction enhancement.
Judge suspended imposition of sentence and placed Kim on formal probation with conditions including obey laws, seek employment and training, and a lifetime firearm prohibition under Penal Code sections 12021 and 12316(b)(1).
The court imposed a $30 court security fee under Penal Code 1465.8 and a $30 criminal conviction assessment under Government Code 70373, in addition to restitution and victim restitution.
Kim did not object to the probation conditions at sentencing and the probation report recommended additional conditions mirroring those imposed.
Kim appealed, arguing (i) the employment condition was not reasonably related to the offense, (ii) the fees/assessments should not be probation conditions, and (iii) the firearm condition lacked a knowledge (scienter) requirement.
The court modified the order to require the fees/assessments be separately imposed and affirmed the judgment with an implicit knowledge requirement for the firearm condition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the employment condition was reasonably related to the offense	Kim contends the employment condition is unrelated to offense and not reasonable.	Kim's position relies on lack of direct relevance given student status; trial court should account for circumstances.	Forfeited; but other issues addressed remain open on merits.
Whether the court security fee and facilities assessment may be imposed as probation conditions	Fees/assessments should not be probation conditions and should be standalone.	The fees/assessments are mandatory financial obligations tied to conviction, not probation.	Should be separately imposed, not made probation conditions.
Whether the no-firearms condition requires an express knowledge (scienter) term	Lack of knowledge requirement makes the condition vague and overbroad.	Implicit knowledge is part of the statutes; no separate knowledge term needed.	Implicit knowledge requirement applies; condition need not be rewritten to add explicit knowledge language.

People v. Welch, 5 Cal.4th 228 (Cal. 1993) (probation conditions must relate to conviction or future criminality)
In re Sheena K., 40 Cal.4th 875 (Cal. 2007) (forfeiture rule and pure questions of law on vagueness/overbreadth)
Pacheco, 187 Cal.App.4th 1392 (Cal. App. 2010) (court security fee not a probation condition; should be separate)
Lopez, 66 Cal.App.4th 615 (Cal. App. 1998) (knowledge of gang status required for association restrictions)
In re Vincent G., 162 Cal.App.4th 238 (Cal. App. 2008) (areas frequented by gang members; knowledge-based modification)