False Domestic Violence Accusations Defense

Falsely accused of domestic violence in San Diego? A DV conviction triggers a custody presumption against you, a firearm ban, and a permanent criminal record. Our defense lawyers fight false accusations aggressively. Call 24/7.

A false domestic violence accusation can dismantle your life in a matter of hours. Not days. Hours. An arrest, an emergency protective order, and suddenly you’re locked out of your own home, separated from your children, and facing criminal charges based on someone else’s word.

The circumstances that lead to false DV accusations are rarely simple. A custody battle where the other parent wants an edge. A bitter breakup where emotions override honesty. An immigration situation where a DV claim opens the door to a visa. A mutual argument where the other person called the police first and controlled the narrative. Sometimes it’s calculated. Sometimes it’s impulsive. Either way, you’re the one sitting in a jail cell.

Charges are accusations, not convictions. The prosecution still has to prove every element beyond a reasonable doubt, and in false accusation cases, the evidence often tells a very different story than the one the accuser is selling.

The fear, the anger, the sense that the system has already decided you’re guilty before you’ve said a word: we get it. What matters now is the defense you build.

At David P. Shapiro Criminal Defense Attorneys, we’ve defended clients throughout San Diego County against domestic violence charges built on lies, exaggerations, and manipulation. We’ve exposed fabricated accusations in cases involving custody disputes, immigration fraud, and post-breakup retaliation. We’ve taken these cases from the initial protective order hearing all the way through jury verdict.

The bottom line is this: San Diego prosecutors pursue DV cases aggressively, and they will proceed even when the accuser recants. You need experienced defense attorneys who understand how these cases actually work, not how they work on television. Time matters. Early action creates options that disappear later.

Quick Reference: False DV Accusation Charges

Element	Details
Primary Charges	PC 273.5 (corporal injury), PC 243(e)(1) (domestic battery), PC 422 (criminal threats)
PC 273.5 Classification	Wobbler (felony or misdemeanor)
PC 243(e)(1) Classification	Misdemeanor
PC 422 Classification	Wobbler; strike offense if charged as felony
Felony Penalties (PC 273.5)	2, 3, or 4 years state prison; fine up to $6,000
Misdemeanor Penalties (PC 273.5)	Up to 1 year county jail; fine up to $6,000
Mandatory Consequences	52-week batterer’s program, 10-year firearm ban, criminal protective order
Custody Impact	Rebuttable presumption against custody (Family Code § 3044)
Immigration Impact	Deportable offense under federal law

How San Diego Prosecutes Domestic Violence Cases

Before we get into specific charges and defenses, you need to understand something critical about how DV cases work in San Diego. This is where most people, including many lawyers, get it wrong.

The Accuser Does Not Control the Case

Here’s the number one misconception we hear: “She’s going to drop the charges” or “He said he’s not going to cooperate, so the case will go away.”

That is not how it works. Not in San Diego. Not even close.

The San Diego District Attorney’s Office and the San Diego City Attorney’s Office make the decision to prosecute, not the alleged victim. Both offices have specialized Domestic Violence Units staffed with prosecutors who handle these cases every single day. They routinely pursue what’s called “victimless prosecution,” meaning they will take your case to trial even when the accuser recants, refuses to cooperate, or begs them to drop the charges.¹

What do they use instead of a cooperative witness? The 911 call recording. Photographs taken at the scene. Statements the accuser made to responding officers. Statements made to medical personnel. Prior statements admitted under Evidence Code Section 1370, which creates a hearsay exception specifically for statements describing the infliction of physical injury.² They build the case around the accuser’s initial statements and the physical evidence, then proceed without the accuser’s participation if necessary.

This is why what happens in the first few hours after an accusation matters so much.

Mandatory Arrest and Protective Orders

San Diego law enforcement agencies follow a pro-arrest policy for domestic violence calls under Penal Code Section 13701.³ What does that look like in practice? Officers respond to a DV call, hear one side of the story, observe redness on the accuser’s arm that could have come from anywhere, and make an arrest. The threshold for arrest is low. The consequences are immediate.

At the scene or shortly after, the arresting officer contacts an on-call judge and obtains an Emergency Protective Order (EPO). That EPO is temporary, lasting five to seven business days, but it can order you out of your own home and prohibit contact with the accuser, your children, or both.⁴

At your arraignment, typically the next business day after arrest, the judge will almost certainly issue a Criminal Protective Order (CPO). This happens before you’ve had any meaningful opportunity to contest the allegations. The CPO can remain in place for the entire duration of the case, which can be months or even years. During that time, you may be prohibited from returning to your residence, contacting your children, or communicating with the alleged victim in any way.

For all intents and purposes, you’re being punished before you’ve been convicted of anything. That’s the reality of how the system works, and it’s exactly why you need experienced defense counsel from the very beginning.

Understanding the Underlying Charges

False DV accusations typically result in charges under one or more of the following statutes. The specific charge depends on what the accuser alleges and what evidence (if any) exists.

Penal Code Section 273.5: Corporal Injury to Spouse or Cohabitant

This is the most commonly charged DV felony. Under PC 273.5, it is a crime to willfully inflict corporal injury resulting in a “traumatic condition” upon a current or former spouse, cohabitant, co-parent, or dating partner.⁵

What does “traumatic condition” mean? It means a condition of the body, such as a wound or external or internal injury, whether minor or serious, caused by physical force.⁶ A bruise counts. Redness counts. Even a minor scratch can qualify. The bar is not high, which is precisely why false accusers can point to minor, self-inflicted, or pre-existing marks and claim abuse.

PC 273.5 is a wobbler, meaning the prosecution can file it as either a felony or a misdemeanor depending on the circumstances and the alleged severity of the injuries.

Penal Code Section 243(e)(1): Domestic Battery

Domestic battery is a misdemeanor charge that does not require any visible injury.⁷ The prosecution only needs to prove that you willfully and unlawfully touched the alleged victim in a harmful or offensive manner, and that the person was your spouse, cohabitant, co-parent, fiancé(e), or dating partner.

No visible injury. No bruise. No mark. Just the accuser’s word that you touched them in a way that was harmful or offensive. You can see how easily this charge lends itself to fabrication.

Penal Code Section 422: Criminal Threats

When the accusation involves alleged verbal threats rather than (or in addition to) physical contact, prosecutors may charge criminal threats under PC 422.⁸ This is a wobbler, and when filed as a felony, it is a strike offense under California’s Three Strikes Law.⁹

To convict, the prosecution must prove that you willfully threatened to kill or cause great bodily injury, that the threat was clear, immediate, unconditional, and specific enough to communicate a serious intention, and that the alleged victim was actually placed in sustained fear that was reasonable under the circumstances.¹⁰

In false accusation cases, the “threat” is often a mischaracterized statement during an argument, taken out of context, or fabricated entirely.

What the Prosecution Must Prove

Regardless of which charge you’re facing, the prosecution bears the burden of proving every element beyond a reasonable doubt. In false accusation cases, this burden is the accused person’s greatest protection.

For PC 273.5 (Corporal Injury), the prosecution must prove ALL of the following:¹¹

1. You willfully inflicted a physical injury on the alleged victim. “Willfully” means on purpose, not by accident. If the injury occurred during an accident or while you were trying to restrain someone acting violently toward you, this element is not met.

2. The injury resulted in a traumatic condition. The prosecution must connect the injury to your actions. Pre-existing injuries, self-inflicted marks, and injuries from other sources all undermine this element.

3. The alleged victim was your spouse, former spouse, cohabitant, former cohabitant, co-parent, or dating partner. The relationship element must be established.

4. You did not act in self-defense or defense of someone else. If we raise self-defense, the prosecution must disprove it beyond a reasonable doubt.

For PC 243(e)(1) (Domestic Battery), the prosecution must prove:¹²

1. You willfully and unlawfully touched the alleged victim in a harmful or offensive manner. Again, “willfully” is key. Accidental contact is not battery.

2. The relationship element. Same categories as above.

3. You did not act in self-defense.

For PC 422 (Criminal Threats), the prosecution must prove:¹³

1. You willfully threatened to kill or cause great bodily injury.

2. The threat was made orally, in writing, or by electronic communication.

3. You intended the statement to be understood as a threat.

4. The threat was clear, immediate, unconditional, and specific.

5. The alleged victim was actually placed in sustained fear.

6. That fear was reasonable under the circumstances.

Every one of these elements is a question mark for the prosecution and an opportunity for the defense. In false accusation cases, the accuser’s credibility is the foundation of the prosecution’s case. When that foundation cracks, the entire case can collapse.

Penalties and Consequences

Criminal Penalties

Charge	Misdemeanor	Felony
PC 273.5 (Corporal Injury)	Up to 1 year county jail; fine up to $6,000	2, 3, or 4 years state prison; fine up to $6,000
PC 243(e)(1) (Domestic Battery)	Up to 1 year county jail; fine up to $2,000	N/A (misdemeanor only)
PC 422 (Criminal Threats)	Up to 1 year county jail	16 months, 2, or 3 years state prison
PC 273.6 (Protective Order Violation)	Up to 1 year county jail; fine up to $1,000	Up to 3 years (with priors + violence)

Sentence Enhancements

If the case involves aggravating factors, the penalties increase dramatically:

Prior DV conviction within 7 years (PC 273.5(f)(1)): Elevated sentencing of 2, 4, or 5 years in state prison.¹⁴

Great bodily injury enhancement (PC 12022.7): 3 to 6 additional years, served consecutively.¹⁵ This enhancement also makes the conviction a strike offense.

Firearm use (PC 12022(b)(1)): 1 additional year.

Strike Implications

PC 422 (criminal threats), when charged as a felony, is a strike offense under California’s Three Strikes Law.¹⁶ A strike on your record means any future felony conviction carries a presumptively doubled sentence. A third strike can result in 25 years to life.

PC 273.5 is generally not a strike offense on its own. However, if the prosecution adds and proves a great bodily injury enhancement, the conviction becomes a serious felony strike.¹⁷

Consequences Beyond Prison

A DV conviction, even a misdemeanor, triggers consequences that extend far beyond the courtroom:

Child Custody. Under Family Code Section 3044, a DV conviction creates a rebuttable presumption against granting custody to the convicted parent.¹⁸ For a falsely accused parent, this is often the most devastating consequence. The very accusation that was fabricated to gain a custody advantage becomes the legal basis for taking your children away.

Firearm Rights. A misdemeanor DV conviction triggers a 10-year firearm prohibition under California law.¹⁹ Under federal law (18 U.S.C. § 922(g)(9)), the prohibition is for life. For military personnel, law enforcement officers, and security professionals in San Diego, this can end a career immediately.

Immigration. Domestic violence is a deportable offense under federal immigration law.²⁰ A conviction can result in removal proceedings, denial of naturalization, or loss of lawful permanent resident status. For non-citizens, the immigration consequences of a DV conviction can be more severe than the criminal penalties.

Professional Licensing. DV convictions can trigger disciplinary proceedings for doctors, nurses, attorneys, teachers, military service members, and anyone holding a professional license or security clearance. In a city with the military presence San Diego has, this consequence is especially significant.

Employment and Housing. A DV conviction appears on background checks and can disqualify you from jobs, housing, and educational opportunities.

Defense Strategies for False DV Accusations

Now let’s talk about what actually matters: how we fight these cases. False accusation defense requires a fundamentally different approach than standard DV defense. The focus shifts from “what happened” to “why is this person lying?”

Exposing the Motive to Fabricate

This is the most powerful defense in false accusation cases, and it’s where experienced defense attorneys separate themselves from everyone else.

People fabricate DV accusations for specific, identifiable reasons. Our job is to find that reason and put it in front of the jury. Common motives include:

Custody advantage. The accuser files a DV report days or weeks before a custody hearing. The timing is not coincidental. A DV conviction triggers the Family Code Section 3044 presumption against custody, and even a pending charge can influence a family court judge’s temporary custody orders.²¹ We investigate the timeline of family court filings relative to the criminal accusation.

Immigration benefit. Under the Violence Against Women Act (VAWA), alleged DV victims can obtain immigration relief through U-visas or VAWA self-petitions. This creates a documented incentive to fabricate or exaggerate abuse claims. We investigate the accuser’s immigration status and any pending applications.

Financial leverage. A protective order can force you out of a shared home, giving the accuser exclusive possession of the residence. In expensive housing markets like San Diego, this is a powerful financial motivator.

Retaliation. Post-breakup anger, jealousy, or a desire to punish the other person. We examine the relationship timeline, communications, and any evidence of the accuser’s hostility.

Preemptive strike. Sometimes the actual aggressor files first to control the narrative. We investigate whether the accuser has a history of violence or aggression.

Inconsistent Statements

False stories are hard to keep straight. We compare every version of the accuser’s account: the 911 call, the statement to responding officers, the written declaration for the protective order, statements to medical personnel, statements to the family court, and testimony at trial.

What changes? What gets added? What gets left out? Inconsistencies don’t just weaken the accuser’s credibility. They can demonstrate fabrication.

We also investigate whether the accuser’s account is consistent with the physical evidence. Did they claim to be punched in the face but have no facial injuries? Did they describe being thrown to the ground but show no bruising consistent with that mechanism? A forensic medical expert can testify that the injuries (if any exist) are inconsistent with the described assault, or consistent with self-infliction.

Digital and Documentary Evidence

In the age of smartphones, Ring doorbells, and social media, digital evidence is often the most powerful tool in false accusation defense. We pursue:

Text messages and emails. Communications between you and the accuser before, during, and after the alleged incident. These often reveal the accuser’s true state of mind, their motive, and sometimes outright admissions of fabrication.

Surveillance and doorbell camera footage. Home security cameras, Ring doorbells, and neighbor cameras can capture what actually happened, or didn’t happen, during the alleged incident.

Cell phone location data and GPS records. If the accuser claims you were present at a specific time and place, cell tower data, GPS records, and even Uber or Lyft records can establish your actual location.

Social media activity. Posts, messages, and timestamps that contradict the accuser’s claims or reveal motive. An accuser who posts about “getting the house” or “winning custody” shortly after filing a DV report is providing evidence of motive.

Financial records. Bank statements, property records, and other financial documents that establish the accuser’s financial incentive to fabricate.

Self-Defense and Dominant Aggressor Analysis

In many false accusation cases, the accused was actually the victim. You were defending yourself, and the other person called the police first.

California law recognizes the right to self-defense, including inside your own home under the Castle Doctrine.²² If you reasonably believed you were in imminent danger of being harmed and used only the force necessary to defend yourself, your actions were lawful.²³

Under Penal Code Section 13701(b), law enforcement is required to conduct a “dominant aggressor” analysis rather than simply arresting both parties or defaulting to arresting the larger or male partner.²⁴ When officers fail to properly identify the dominant aggressor, we can, and will, challenge that failure if the facts support a position to do so.

Challenging Victimless Prosecution

When the accuser recants or refuses to cooperate, the prosecution relies on prior statements and physical evidence. We challenge this evidence at every turn:

Confrontation Clause. Under Crawford v. Washington, testimonial hearsay statements are inadmissible unless the declarant is unavailable and the defendant had a prior opportunity for cross-examination.²⁵ If the accuser made statements to police during a structured interrogation rather than during an ongoing emergency, those statements may be inadmissible.

Evidence Code Section 1370. This hearsay exception allows the prosecution to admit the accuser’s prior statements describing the infliction of physical injury, even without the accuser’s testimony.²⁶ We challenge the foundational requirements for this exception: the statement must have been made at or near the time of the infliction, and the statement must have been made under circumstances indicating trustworthiness. Fabricated statements made to build a false case may not meet these requirements.

Fourth Amendment challenges. If officers entered your home without a warrant or arrested you based solely on the accuser’s uncorroborated statement without sufficient probable cause, we challenge the legality of the arrest and seek suppression of evidence obtained as a result.

Expert Testimony

In appropriate cases, expert witnesses can be critical:

Forensic medical experts can testify that alleged injuries are inconsistent with the described assault, consistent with self-infliction, or attributable to other causes.

Digital forensics experts can authenticate or challenge digital evidence, recover deleted communications, and establish timelines.

Domestic violence dynamics experts can educate the jury on how and why false accusations occur, the motivations behind them, and the patterns that distinguish genuine victims from fabricators.

The First 72 Hours: What Happens and What to Do

Understanding the timeline helps you take control of a chaotic situation.

Hour 0-4: Arrest and EPO. Officers respond to the DV call, hear the accuser’s version, and make an arrest under San Diego’s pro-arrest policy. An Emergency Protective Order is obtained from an on-call judge. You are booked into county jail.

Hour 4-24: Bail and release. For misdemeanor DV, you may be released on your own recognizance or after posting bail. For felony charges, bail amounts vary. The EPO prohibits you from returning home or contacting the accuser.

Day 1-2: Arraignment. You appear in court. The judge will almost certainly issue a Criminal Protective Order that replaces the EPO. The CPO may be a “full no-contact” order or a “peaceful contact” order, depending on the circumstances. This is your first opportunity to have defense counsel argue for the least restrictive order possible.

Day 2-7: Critical evidence window. This is when evidence preservation matters most. Surveillance footage gets overwritten. Text messages get deleted. Witnesses’ memories fade. The sooner your defense team begins investigating, the more evidence we can preserve and the more options you have.

What should you do during this time? Keep your mouth closed. Do not contact the accuser, even if they contact you first. Violating the protective order is a separate criminal charge under PC 273.6, regardless of who initiated the contact.²⁷ Do not post about the case on social media. Do not discuss the case with anyone except your attorney. Contact experienced criminal defense counsel immediately.

Parallel Proceedings: Criminal Court and Family Court

False DV accusations rarely exist in a vacuum. If you share children or property with the accuser, the criminal case is likely running alongside family court proceedings. This creates a strategic minefield.

Statements you make in family court can be used against you in criminal court. A declaration filed in a custody proceeding, a statement made during a mediation session, testimony at a DVRO hearing: all of it can potentially be used by the prosecution.

Conversely, the criminal protective order can affect your family court case. If the CPO prohibits contact with the accuser, it can complicate custody exchanges, co-parenting communication, and access to your children.

Coordinating the criminal defense with the family court strategy is essential. Many attorneys handle one or the other. Few handle both competently. This is an area where having defense counsel who understands the full picture makes a measurable difference.

Related Charges and Offenses

Commonly Co-Charged Offenses

DV cases rarely involve a single charge. Prosecutors frequently stack charges to increase leverage:

Child endangerment (PC 273a) when children were present during the alleged incident. Violation of a protective order (PC 273.6) if any post-arrest contact occurred. Vandalism (PC 594) if property damage is alleged. False imprisonment (PC 236) if the accuser claims you prevented them from leaving.

The False Police Report Statute

Penal Code Section 148.5 makes it a misdemeanor to file a false police report.²⁸ While prosecutors rarely charge accusers with filing false reports in DV cases, the existence of this statute is relevant context. It establishes that the law recognizes false reporting as a real and punishable problem, and evidence that the accuser violated this statute can be powerful impeachment material.

Lesser Offenses

In some cases, negotiating a resolution to a non-DV offense is the best strategic outcome. Disturbing the peace under PC 415 is not a domestic violence offense, does not trigger the firearm ban, does not trigger the Family Code Section 3044 custody presumption, and does not carry the same collateral consequences. The difference between a DV conviction and a non-DV resolution can be the difference between keeping your career, your custody rights, and your gun rights, or losing all three.

Facing False DV Accusations in San Diego?

False domestic violence accusations require defense attorneys who understand both the criminal case and the family court case, because in San Diego, these cases are almost always connected. We’ve defended clients against fabricated accusations driven by custody disputes, immigration motives, financial leverage, and outright retaliation. We know how San Diego’s specialized DV prosecution units operate, we know how to challenge victimless prosecution, and we know how to expose the accuser’s true motive. Evidence fades. Witnesses forget. The window for the strongest defense is now.

Call us 24/7 for a consultation. We’ll review the facts of your case, explain what you’re actually facing, and start building your defense immediately. The prosecution is already building their case. It’s time to build yours.

References

1. 1. See Penal Code, § 13701 [law enforcement domestic violence policies; pro-arrest policy].↑ See Penal Code, § 13701 [law enforcement domestic violence policies; pro-arrest policy].
2. 2. Evidence Code, § 1370 [hearsay exception for statements describing infliction of physical injury].↑ Evidence Code, § 1370 [hearsay exception for statements describing infliction of physical injury].
3. 3. Penal Code, § 13701, subd. (b) [dominant aggressor analysis; law enforcement response policies].↑ Penal Code, § 13701, subd. (b) [dominant aggressor analysis; law enforcement response policies].
4. 4. See Family Code, § 6250 et seq. [emergency protective orders].↑ See Family Code, § 6250 et seq. [emergency protective orders].
5. 5. Penal Code, § 273.5, subd. (a) [“Any person who willfully inflicts corporal injury resulting in a traumatic condition upon a victim described in subdivision (b) is guilty of a felony…”].↑ Penal Code, § 273.5, subd. (a) [“Any person who willfully inflicts corporal injury resulting in a traumatic condition upon a victim described in subdivision (b) is guilty of a felony…”].
6. 6. Penal Code, § 273.5, subd. (d) [“‘Traumatic condition’ means a condition of the body, such as a wound, or external or internal injury, including, but not limited to, injury as a result of strangulation or suffocation, whether of a minor or serious nature, caused by a physical force.”].↑ Penal Code, § 273.5, subd. (d) [“‘Traumatic condition’ means a condition of the body, such as a wound, or external or internal injury, including, but not limited to, injury as a result of strangulation or suffocation, whether of a minor or serious nature, caused by a physical force.”].
7. 7. Penal Code, § 243, subd. (e)(1).↑ Penal Code, § 243, subd. (e)(1).
8. 8. Penal Code, § 422 [criminal threats].↑ Penal Code, § 422 [criminal threats].
9. 9. Penal Code, § 1192.7, subd. (c)(38) [criminal threats as serious felony].↑ Penal Code, § 1192.7, subd. (c)(38) [criminal threats as serious felony].
10. 10. See CALCRIM No. 1300 [Criminal Threats].↑ See CALCRIM No. 1300 [Criminal Threats].
11. 11. See CALCRIM No. 840 [Inflicting Corporal Injury on Spouse or Cohabitant].↑ See CALCRIM No. 840 [Inflicting Corporal Injury on Spouse or Cohabitant].
12. 12. See CALCRIM No. 841 [Battery Against Spouse, Cohabitant, or Fellow Parent].↑ See CALCRIM No. 841 [Battery Against Spouse, Cohabitant, or Fellow Parent].
13. 13. See CALCRIM No. 1300 [Criminal Threats].↑ See CALCRIM No. 1300 [Criminal Threats].
14. 14. Penal Code, § 273.5, subd. (f)(1) [enhanced penalties for prior DV convictions within 7 years].↑ Penal Code, § 273.5, subd. (f)(1) [enhanced penalties for prior DV convictions within 7 years].
15. 15. Penal Code, § 12022.7 [great bodily injury enhancement].↑ Penal Code, § 12022.7 [great bodily injury enhancement].
16. 16. Penal Code, § 1192.7, subd. (c)(38) [criminal threats as serious felony].↑ Penal Code, § 1192.7, subd. (c)(38) [criminal threats as serious felony].
17. 17. Penal Code, § 1192.7, subd. (c)(8) [any felony in which defendant personally inflicts great bodily injury as serious felony].↑ Penal Code, § 1192.7, subd. (c)(8) [any felony in which defendant personally inflicts great bodily injury as serious felony].
18. 18. Family Code, § 3044 [rebuttable presumption against custody for person convicted of domestic violence].↑ Family Code, § 3044 [rebuttable presumption against custody for person convicted of domestic violence].
19. 19. Penal Code, § 29805 [10-year firearm prohibition for specified misdemeanor convictions].↑ Penal Code, § 29805 [10-year firearm prohibition for specified misdemeanor convictions].
20. 20. See 8 U.S.C. § 1227(a)(2)(E) [deportability for domestic violence offenses].↑ See 8 U.S.C. § 1227(a)(2)(E) [deportability for domestic violence offenses].
21. 21. Family Code, § 3044 [rebuttable presumption against custody for person convicted of domestic violence].↑ Family Code, § 3044 [rebuttable presumption against custody for person convicted of domestic violence].
22. 22. Penal Code, § 198.5 [presumption of reasonable fear in the home; Castle Doctrine].↑ Penal Code, § 198.5 [presumption of reasonable fear in the home; Castle Doctrine].
23. 23. See CALCRIM No. 3470 [Right to Self-Defense].↑ See CALCRIM No. 3470 [Right to Self-Defense].
24. 24. Penal Code, § 13701, subd. (b) [dominant aggressor analysis; law enforcement response policies].↑ Penal Code, § 13701, subd. (b) [dominant aggressor analysis; law enforcement response policies].
25. 25. <em>Crawford v. Washington</em> (2004) 541 U.S. 36 [confrontation clause; testimonial hearsay].↑ <em>Crawford v. Washington</em> (2004) 541 U.S. 36 [confrontation clause; testimonial hearsay].
26. 26. Evidence Code, § 1370 [hearsay exception for statements describing infliction of physical injury].↑ Evidence Code, § 1370 [hearsay exception for statements describing infliction of physical injury].
27. 27. Penal Code, § 273.6 [violation of protective order].↑ Penal Code, § 273.6 [violation of protective order].
28. 28. Penal Code, § 148.5 [filing a false police report].↑ Penal Code, § 148.5 [filing a false police report].