California Codes

Cal. Penal Code § 23 (2026)

Preliminary Provisions

✓ leginfo export of Sept. 26, 2026 (applied Oct. 1, 2026)
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In any criminal proceeding against a person who has been issued a license to engage in a business or profession by a state agency pursuant to provisions of the Business and Professions Code or the Education Code, or the Chiropractic Initiative Act, the state agency which issued the license may voluntarily appear to furnish pertinent information, make recommendations regarding specific conditions of probation, or provide any other assistance necessary to promote the interests of justice and protect the interests of the public, or may be ordered by the court to do so, if the crime charged is substantially related to the qualifications, functions, or duties of a licensee.

For purposes of this section, the term “license” shall include a permit or a certificate issued by a state agency.

For purposes of this section, the term “state agency” shall include any state board, commission, bureau, or division created pursuant to the provisions of the Business and Professions Code, the Education Code, or the Chiropractic Initiative Act to license and regulate individuals who engage in certain businesses and professions.

Notes of Decisions
Cited in 5 cases (1 in the last 5 years), 2005–2021 · leading case: Naidu v. Superior Court of Riverside Cnty., 20 Cal. App. 5th 300 (Cal. Ct. App. 2018).
Naidu v. Superior Court of Riverside Cnty., 20 Cal. App. 5th 300 (Cal. Ct. App. 2018). · cites it 2× “Penal Code section 23 reads, as relevant: "In any criminal proceeding against a person who has been issued a license to engage in a business or profession by a state agency pursuant to provisions of the Business and Professions Code or the Education Code, or the Chiropractic…”
Gray v. Superior Court, 125 Cal. App. 4th 629 (Cal. Ct. App. 2005). “Among other things, Penal Code section 23 authorizes a state licensing agency to “make recommendations regarding specific conditions of probation .”
Naidu v. Superior Court, No. E068437 (Cal. Ct. App. Feb. 7, 2018). · cites it 3× “We briefly discuss these statutory underpinnings before addressing due process principles, more generally.”
People v. Zhou, No. B301601 (Cal. Ct. App. Jan. 15, 2021). “) 4 As relevant here, Penal Code section 23 provides that “In any criminal proceeding against a person who has been 16 invalid simply because the Board purported to appear pursuant to that section.”
(HC) Gray v. Muniz, No. 2:16-cv-01577 (E.D. Cal. Mar. 26, 2020). “” (Pen.Code, § 23 1089.) “Once a trial court is put on notice that good cause to discharge a juror may exist, it is the court's duty ‘to make whatever 24 inquiry is reasonably necessary’ to determine whether the juror should be discharged.”
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