In People v. Ceballos (1974) 12 Cal.3d 470, the defendant was convicted of assault with a deadly weapon after a trap gun that he mounted in his garage discharged a bullet into the face of a teenager who broke into the defendant's garage. On appeal, the defendant argued, among other things, that he acted in lawful defense of his property because, had he been present, he would have been authorized by section 197 to shoot the victim in order to resist commission of a felony. The Ceballos court disagreed. The court explained that "by its terms subdivision 1 of Penal Code section 197 appears to permit killing to prevent any 'felony,' but in view of the large number of felonies today and the inclusion of many that do not involve a danger of serious bodily harm, a literal reading of the section is undesirable." (Ceballos, supra, 12 Cal.3d at p. 477-478.) Therefore, the court approved lower court authority that had construed section 197 in light of the common law limitation that a killing or use of deadly force to prevent a felony could be justified only if the offense was a "forcible and atrocious crime." (Id. at p. 478.) Ultimately, the court concluded that the victim in the case before it did not commit a forcible and atrocious crime. (Ibid.)