In re H.R. CA3
The juvenile court found H.R. (the minor) committed a lewd or lascivious act on a child under the age of 14 by means of force, violence, duress, menace, or threat of great bodily injury (Pen. Code, § 288, subd. (b)(1)).1 On appeal, the minor contends substantial evidence does not support either of the prosecution’s theories that he acted with force or duress. Under the applicable and deferential substantial evidence standard of review,



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