People v. Sparks

Posing as a magazine salesman, Sparks (defendant) talked his way into Ana I.'s single-family home; when Ana went to her bedroom to get shoes so she could leave to pick up her niece, Sparks followed her in, shoved her onto the bed, and raped her. The trial court instructed the jury that entering any room with intent to commit a felony satisfies burglary, and Sparks was convicted of first-degree burglary and forcible rape. The court of appeal reversed the burglary conviction, holding that entering an unsecured bedroom within a single-family home did not meet burglary's entry requirement, and the State appealed.