Dec. 13, 2022 – People v. Johnson (1st. Dist., Div. 1, A163941)

A jury convicted defendant of arson (PC 451) and sustained an enhancement under PC 451.1 after she was found to have poured whiskey onto a house’s cat door and lit the whiskey on fire. The Court of Appeal rejects the challenge to the enhancement, holding that whiskey, like gasoline, is a flammable liquid that qualifies as a “device designed to accelerate the fire” under PC 451.1(a)(5).