California Penal Code Section 266i - Interpretation

In People v. Bradshaw (1973) 31 Cal.App.3d 421, the seminal case interpreting section 266i, the defendant "encouraged" an undercover policewoman to become a prostitute by having three conversations with her concerning entering a house of prostitution under his supervision, and splitting her profits with him. The court determined that section 266i was not limited to recruiting "innocent women" into the field of prostitution. It construed the statute to include the solicitation of a woman "who the defendant believes presently to be a prostitute to change her business relations." (People v. Bradshaw, supra, 31 Cal.App.3d at p. 426.) In People v. Hashimoto (1976) 54 Cal.App.3d 862, an undercover policewoman posed as a prostitute to investigate claims of prostitution. She contacted the defendant, who owned a travel agency. He offered to provide her with a steady supply of clients if she would agree to a lower price for her services. The court held that, by making the proposal, the defendant was inducing or encouraging a female to continue in the profession and "change her business relations by reducing her price in exchange for volume." (Id. at p. 866.)