People v. Brandao

In People v. Brandao (2012) 203 Cal.App.4th 436, the court refused to apply this analysis to a violation of section 647.6, subdivision (a). The court noted that, while a section 647.6, subdivision (a) violation can potentially involve conduct that is much less overtly sexual than the felony sex offenses found subject to discretionary registration in Hofsheier, a conviction under section 647.6, subdivision (a) requires conduct that would unhesitatingly irritate or disturb a reasonable person. (Brandao, supra, 203 Cal.App.4th at p. 445.)