People v. V.V., 51 Cal. 4th 1020

V.V. and J.H., both 17, ignited and threw a large firecracker onto a brush-covered hillside in Pasadena, starting a five-acre brush fire.
Witnesses identified V.V. and J.H. as the individuals running from the scene; Ramirez and Moujoukian provided identifications at field showups and adjudicatory hearings.
V.V. admitted causing the fire; statements during Miranda interviews indicate both minors discussed lighting the firecracker and allegedly attempted to avoid or minimize harm.
The juvenile court concluded the act was willful and intentional but found malice met under Atkins despite no intent to burn the hillside.
Division One of the Court of Appeal affirmed arson for V.V. but Division Eight reversed as to J.H., concluding he did not act with malice under Atkins.
The Supreme Court consolidated the cases to resolve the proper application of Atkins to malice in arson.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does malice exist in arson when the act is intentional but there is no intent to burn?	V.V. and J.H. acted willfully; malice may be inferred from intent to commit a wrongful act under Atkins.	No malice; the acts were not purposeful to injure or burn; arson requires malice beyond a general intent.	Yes; malice established under Atkins
May malice be inferred from deliberate ignition and throwing of a firecracker into dry brush under Atkins?	Deliberate ignition into a high-fire-risk area supports malice and the direct, natural, and probable consequence of burning forest land.	Inference of malice from act itself is insufficient without a wrongful intent; need explicit or implied wrongfulness.	Malice inferred; arson affirmed for V.V., reversed for J.H. on remand

People v. Atkins, 25 Cal.4th 76 (Cal. 2001) (arson is a general intent crime; malice can be inferred from deliberate conduct under circumstances)
U.S. v. Doe, 136 F.3d 631 (9th Cir. 1998) (malice may be proven by deliberate act causing fire without justification; supports Atkins framework)
People v. Hayes, 120 Cal.App.4th 796 (Cal. App. Dist. 2) (malice may be inferred from the nature of injuries and intentional acts)
People v. Wyatt, 48 Cal.4th 776 (Cal. 2010) (defendant need not know his act is socially prohibited to be liable for certain offenses)
People v. Fry, 19 Cal.App.4th 1334 (Cal. App. Dist. 2) (illustrates distinguishing willful arson from reckless fire setting)
People v. Rocha, 3 Cal.3d 893 (Cal. 1971) (early analysis of malice and willfulness in arson context)
Bohmer, 46 Cal.App.3d 185 (Cal. App. Dist. 3) (malice considerations in ignition-related offenses)