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Cal. Penal Code § 32 (2026)

✓ current as of May 2026
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Every person who, after a felony has been committed, harbors, conceals or aids a principal in such felony, with the intent that said principal may avoid or escape from arrest, trial, conviction or punishment, having knowledge that said principal has committed such felony or has been charged with such felony or convicted thereof, is an accessory to such felony.

Notes of Decisions
Cited in 180 cases (29 in the last 5 years), 1953–2026 · leading case: Navarro-Lopez v. Gonzales, 503 F.3d 1063 (9th Cir. 2007).
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Navarro-Lopez v. Gonzales, 503 F.3d 1063 (9th Cir. 2007). · cites it 24× “PREGERSON, Circuit Judge: Armando Navarro-Lopez petitions for review of a final order of removal, arguing that the Board of Immigration Appeals ("BIA") erred in summarily affirming the immigration judge's ("IJ") determination that Navarro-Lopez's conviction under California…”
Augustin Valenzuela Gallardo v. Loretta E. Lynch, 818 F.3d 808 (9th Cir. 2016). · cites it 22× “838 (BIA 2012), holding that a conviction for accessory to a felony under California Penal Code § 32 is an aggravated felony “offense relating to obstruction of justice” under Immigration and Nationality Act § 101(a)(43)(S).”
United States v. Vidal, 504 F.3d 1072 (9th Cir. 2007). · cites it 12× “he majority concludes that the word "accessory" in California Vehicle Code § 10851(a) means that the statute must necessarily include accessory after the fact liability despite a lack of evidence that California has ever interpreted the statute this broadly, and despite ample…”
Agustin Valenzuela Gallardo v. William Barr, 968 F.3d 1053 (9th Cir. 2020). · cites it 19× “In a prior published opinion, the BIA found Valenzuela Gallardo removable on the ground that his conviction for being an accessory to a felony, in violation of California Penal Code § 32, was an obstruction of justice aggravated felony under 8 U.”
People v. Gordon, 792 P.2d 251 (Cal. 1990). · cites it 6× “" (Pen. Code, § 32.) To be sure, Rauch did not expressly admit either intent or knowledge.”
United States v. Aguila-Montes De Oca, 655 F.3d 915 (9th Cir. 2011). · cites it 4× “In Navarro-Lopez , we addressed the question of whether a conviction under California Penal Code § 32 for accessory after the fact was a crime involving moral turpitude.”
United States v. Jennings, 515 F.3d 980 (9th Cir. 2008). · cites it 4× “2007) (en banc), we considered whether a conviction under Cal.Penal Code § 32 (accessory after the fact), was a crime involving moral turpitude ("CIMT").”
People v. Partee, 456 P.3d 437 (Cal. 2020). · cites it 3× “) He observed that “[n]o California case has ever sanctioned use of Penal Code section 32 . . . to mete out felony punishment for a witness who merely opts to remain silent (as distinguished from a witness who affirmatively tells some falsehood in a police interview or while on…”
People v. Rodrigues, 885 P.2d 1 (Cal. 1994). · cites it 2× “[59] Penal Code section 32 provides as follows: "Every person who, after a felony has been committed, harbors, conceals or aids a principal in such felony, with the intent that said principal may avoid or escape from arrest, trial, conviction or punishment, having knowledge that…”
United States v. Aguila-Montes De Oca, 553 F.3d 1229 (9th Cir. 2009). · cites it 6× “In Navarro-Lopez , the defendant pleaded guilty to one count of California Penal Code section 32, accessory after the fact.”
Petrilli v. Leapley, 491 N.W.2d 79 (S.D. 1992). · cites it 6× “Cal.Penal Code § 32 provides: Every person who, after a felony has been committed, harbors, conceals or aids a principal in such felony, with the intent that said principal may avoid or escape from arrest, trial, conviction or punishment, having knowledge that said principal has…”
Armando Navarro-Lopez v. Alberto R. Gonzales, Attorney Gen., 455 F.3d 1055 (9th Cir. 2006). · cites it 8× “LEAVY, Circuit Judge: Armando Navarro-Lopez petitions for review of a final order of removal, arguing that the Board of Immigration Appeals (BIA) erred in summarily affirming the immigration judge’s (IJ) determination that Navarro-Lopez’s conviction under California Penal Code §…”
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