In People v. Valencia (2002) 28 Cal.4th 1, a neighbor observed the defendant using a screwdriver to remove a window screen from a bathroom window and trying unsuccessfully to open the window itself. The defendant had also evidently pulled a window screen away from a bedroom window and tried unsuccessfully to open that window as well. Several pry marks were also found on the bathroom window that could have been made by the defendant's screwdriver. (Valencia, supra, 28 Cal.4th at pp. 4-5.) After the close of evidence, the trial court instructed the jury on entry for burglary as follows: "'Any kind of entry, partial or complete, will satisfy the element of entry. The entry may be made by any part of the body or by use of an instrument or tool. In order for there to have been an entry, a part of the defendant's body or some instrument, tool or other object under his control must have penetrated the area inside where the screen was normally affixed in the window frame in question.'" (Id. at p. 5.) Our Supreme Court found no error in the instruction, holding that "penetration into the area behind a window screen amounts to an entry of a building within the meaning of the burglary statute even when the window itself is closed and is not penetrated." (Id. at pp. 12-13.) he California Supreme Court granted review "to determine whether penetration into the area behind a window screen amounts to an entry of a building within the meaning of the burglary statute when the window itself is closed and is not penetrated." (Valencia, supra, 28 Cal.4th at pp. 3-4.) The defendant "removed a window screen from a bathroom window of the . . . house and tried unsuccessfully to open the window itself." (Valencia, supra, 28 Cal.4th at p. 4.) At the outset, the court noted that California has "greatly expanded" the common law definition of burglary as the breaking and entering of a dwelling in the nighttime. (Id. at p. 7.) Under California's more expansive burglary law, "'there is no requirement of a breaking; an entry alone is sufficient. The crime is not limited to dwellings, but includes entry into a wide variety of structures. The crime need not be committed at night.'" (Ibid.) Furthermore, the Valencia court observed, "'"burglary remains an entry which invades a possessory interest in a building.". . . . "'Burglary laws are based primarily upon a recognition of the dangers to personal safety created by the usual burglary situation--the danger that the intruder will harm the occupants in attempting to perpetrate the intended crime or to escape and the danger that the occupants will in anger or panic react violently to the invasion, thereby inviting more violence. The laws are primarily designed, then, not to deter the trespass and the intended crime, which are prohibited by other laws, so much as to forestall the germination of a situation dangerous to personal safety.' The burglary statute, in short, is aimed at the danger caused by the unauthorized entry itself."'" (Ibid.) In Valencia, the Supreme Court granted review "to determine whether penetration into the area behind a window screen amounts to an entry of a building within the meaning of the burglary statute when the window itself is closed and is not penetrated." (Valencia, supra, 28 Cal.4th at pp. 3-4.) As its starting point, the court noted that California has "greatly expanded" the common law definition of burglary as the breaking and entering of a dwelling in the nighttime. (Id. at p. 7.) Under California's more expansive burglary law, "'there is no requirement of a breaking; an entry alone is sufficient. The crime is not limited to dwellings, but includes entry into a wide variety of structures. The crime need not be committed at night.'" (Ibid.) With that in mind, the Supreme Court turned to the question of whether penetration into an area behind a window screen "amounts to an entry of a building." (Valencia, supra, 28 Cal.4th at p. 8.) The court stated that where "the outer boundary of a building for purposes of burglary is not self-evident, ... a reasonable belief test generally may be useful in defining the building's outer boundary. Under such a test, in dealing with items such as a window screen, a building's outer boundary includes any element that encloses an area into which a reasonable person would believe that a member of the general public could not pass without authorization. ... The test reflects and furthers the occupant's possessory interest in the building and his or her personal interest in freedom from violence that might ensue from unauthorized intrusion." (Id. at p. 11.)