People v. M.M., 54 Cal. 4th 530

January 30, 2008: school security officers responded to vandalism on campus; minor fled and was later arrested after confrontation with officer Yanez.
Amended petition charged minor with resisting a public officer (school security officer) under Penal Code §148(a)(1) and vandalism.
Juvenile court found school security officer a public officer under §148(a)(1) and true the §148(a)(1) allegation; minor placed on probation.
Court of Appeal reversed, holding school security officer not a public officer under §148(a)(1) based on Rosales and Olsen.
Supreme Court granted review to resolve whether school security officers fall within the protection of §148(a)(1) and reverse the Court of Appeal.
Court held school security officers are public officers under §148(a)(1) and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a school security officer is a public officer under §148(a)(1).	People contends yes; school security officers perform law enforcement-related duties.	M.M. contends no; school security officers lack tenured public office.	Yes; school security officers are public officers under §148(a)(1).

Coulter v. Pool, 187 Cal. 181 (Cal. 1921) (defined public officer/public office concepts underpinning the analysis)
Spreckels v. Graham, 194 Cal. 516 (Cal. 1924) (acknowledged flexibility in defining public officer/public office)
In re William F., 11 Cal.3d 249 (Cal. 1974) (recognizes peace officers as public officers)
Olsen v. City of Oakland, 186 Cal.App.3d 257 (Cal. App. Dist. 2) (examined public officer scope in context of emergency responders)
Rosales v. State, 129 Cal.App.4th 81 (Cal. App. Dist. 2) (discussed limits of public officer concept in other statutory contexts)
People v. Woodhead, 43 Cal.3d 1002 (Cal. 1987) (acknowledged ostensible objects/policy in statutory interpretation)