There ain't anything in the statute that makes such a distinction.
I've never seen a case where PC 537e has been charged, absent there being a larger context to the criminal case.
The most common application of section 537e is where a nice LEO finds a knucklehead with a bunch of stuff that is most likely stolen, and where follow-up investigation is needed to establish that the stuff is stolen. For instance, I might make a traffic stop for a B/O taillight and then find 50 car stereos in the trunk, with the serial numbers removed, while checking the taillight wiring. In that case, someone is going to jail for 537e while we check the stack of auto burglary reports to see if any of the stereos match a stolen report.
While an arrest for 537e, based only on a S/N being covered by a firearm accessory may be lawful, it's hard to reconcile with the enforcement guidance of Penal Code section Four.
I've never seen a case where PC 537e has been charged, absent there being a larger context to the criminal case.
The most common application of section 537e is where a nice LEO finds a knucklehead with a bunch of stuff that is most likely stolen, and where follow-up investigation is needed to establish that the stuff is stolen. For instance, I might make a traffic stop for a B/O taillight and then find 50 car stereos in the trunk, with the serial numbers removed, while checking the taillight wiring. In that case, someone is going to jail for 537e while we check the stack of auto burglary reports to see if any of the stereos match a stolen report.
While an arrest for 537e, based only on a S/N being covered by a firearm accessory may be lawful, it's hard to reconcile with the enforcement guidance of Penal Code section Four.

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