In Greenberg v. Superior Court (1942) 19 Cal.2d 319, which predated the enactment of section 995, the California Supreme Court held that an indictment was subject to review for "some evidence" to support it. (Greenberg, supra, at p. 322.) The Greenberg defendant had filed a petition for writ of prohibition, claiming no evidence supported an indictment charging him with conspiracy to commit grand theft. The court rejected the district attorney's claim that writ relief was unavailable. The court noted that while at common law a grand jury indictment was "unimpeachable," the reason for this rule ceased to exist when transcripts began to be kept and made available to both the defendant and the prosecution. (Ibid.) In reaching its conclusion regarding the availability of writ review in grand jury proceedings, the Greenberg court discussed In re Kennedy (1904) 144 Cal. 634, in which "a defendant petitioned for a writ of habeas corpus on the ground that the uncorroborated testimony of an accomplice, which constituted the evidence presented to the grand jury, was insufficient to justify an indictment." (Greenberg, supra, 19 Cal.2d at p. 322.) The Greenberg court pointed out that at the time of the Kennedy decision, transcripts of grand jury proceedings were not available to the defendants, and it held that therefore, "The Kennedy court properly refused the writ, holding, in accordance with the general rule, that it would not inquire into the sufficiency of the evidence." (Ibid.)