I dissented in In re Lawrence (2008) 44 Cal.4th 1181 [82 Cal.Rptr.3d 169, 190 P.3d 535] (Lawrence). I believed then, and still believe, the majority opinion in that case was ill considered. Lawrence is largely responsible for the confusion in the Courts of Appeal that today’s opinion seeks to ameliorate. However, my view in Lawrence did not prevail, and I now accept the majority view. For this reason, I concur entirely in this case.