Obstruction

VC31

Constitutionality

To avoid a violation of the federal and state due process clauses, the statute criminalizing the making of false statements to peace officers “while in the performance” of their duties under the Vehicle Code is deemed to prohibit deceit only as to a material fact pertinent to an investigatory matter undertaken by a peace officer pursuant to the Vehicle Code. U.S. Const. Amend. 14; Cal. Const. art. 1, § 7; Cal. Veh. Code § 31. (People v. Morera-Munoz (2016) 5 Cal.App.5th 838.)