In re V.V.

Three minors, including V.V. and J.H. (defendants), climbed a brush-covered hill; V.V. lit a firecracker and J.H. threw it down the hill (the third minor abstained over safety concerns), sparking a fire that burned five acres of brush. Both admitted to lighting the firecracker to make noise, and each claimed to have aimed for an area less likely to ignite (V.V. said green brush, J.H. said a concrete area). Prosecutors pursued juvenile arson charges, or alternatively the lesser offense of recklessly causing a fire; the juvenile court found arson and made both wards of the state. On appeal, one appellate division affirmed V.V.'s wardship while another reversed J.H.'s, disagreeing over whether intentionally lighting and throwing the firecracker satisfied arson's malice requirement. The California Supreme Court took up both cases.