Is there a distinction between an attached garage with an outside door for purposes of determining the degree of burglary?

"There is no meaningful distinction between an attached garage with an outside door and an attached garage with an inside door for purposes of deciding the degree of burglary. The close physical proximity of an attached structure is precisely what increases the potential for confrontation and threatens the safety of residents. This potential is no less when access to the garage is from outside rather than from inside the house. The proper focus is whether the attached structure is an integral part of a dwelling; that is, functionally interconnected with and immediately contiguous to other portions of the house. (People v. Moreno [(1984)] 158 Cal.App.3d [109, 112].) The absence of an inside door does not compel a designation of second degree burglary." (People v. Ingram, supra, 40 Cal.App.4th at p. 1404.)

People v. Moreno (1984) 158 Cal.App.3d 109, likewise held that a garage under the same roof as the living quarters, contiguous and functionally interconnected with other parts of the home, was part of an inhabited dwelling, even though there was no door connecting the garage to the interior of the house. (Id. at p. 112.)