The California Supreme Court affirmed a court of appeal judgment. The court held that provisions of Penal Code §424, which criminalizes acting without authority or failing to act as required by law or legal duty, require proof a defendant knew, or was criminally negligent in failing to know, the legal requirements that governed the act or omission.

Sutter County auditor-controller Robert Stark was indicted on criminal charges stemming from a “turf battle” with other county officials regarding accounting matters. In addition, Stark was accused under Gov. Code §3060 in an attempt to remove him from office for willful misconduct.