In People v. Behjat (2000) 84 Cal. App. 4th Supp. 1, the three-judge panel agreed that a conviction for violating Vehicle Code section 22350 had to be reversed for lack of substantial evidence, but split on the significance of Vehicle Code section 22351 in a "basic speed law" prosecution. In footnote 3 of the Behjat majority opinion, the court noted the People's case had been made more difficult because of their failure to charge under a more specific statute, such as Vehicle Code section 22351. The concurring opinion reasoned, however, that section 22351 is not a charging statute but merely a statute to allocate the burden of proof in prosecutions under section 22350.