Garcia

*213 Defendant Pedro G. Garcia, while staying as a guest in his sister-in-law's home, forcibly raped and sodomized his 12-year-old niece, who was also his sister-in-law's guest and family member. He was convicted by a jury of forcible sex crimes, including a forcible lewd act against a child under the age of 14 in the course of a first *914 degree burglary. The burglary finding led to a statutorily mandated sentence of life without parole under the "One Strike" law and is at the crux of many of defendant's challenges. His principal argument is that the burglary finding cannot stand because he was *214 an invited overnight guest in the home and bedroom where he forced himself on his young niece. The law, however, is to the contrary.

At first blush, defendant's argument has some appeal since we commonly associate burglary with strangers breaking and entering a home and not with acts by invited guests. But our burglary statute, Penal Code section 459, 1 reaches beyond this common understanding to punish any entry into a home or a room within a home, so long as the person enters with the intent to commit a felony and without the authority to do so. Our case law confirms the statute's…