People v. Bailey
Annotate this CaseDefendant, a prison inmate, was charged with escape from custody. However, Defendant only broke out of his cell and breached interior security barriers. The jury found Defendant guilty of escape from prison without force or violence. The court of appeal reversed, finding insufficient evidence of escape and concluding that the term "escape" under the relevant statute required an actual escape beyond the outer boundary of the prison facility having custody of that prisoner. The court refused to modify the escape conviction to attempt to escape. The Supreme Court affirmed, holding that the court of appeal correctly determined it could not modify the escape conviction to an attempt to escape, as the record contained evidence that could lead a rational jury to find the element of specific intent lacking.
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