People v. Saephanh, 80 Cal. App. 4th 451, 94 Cal. Rptr. 910 (2001), is a United States criminal case in which it was determined that solicitation of another person to commit a crime can occur even if the solicitation is never communicated to that person.Criminal Law - Cases and Materials, 7th ed. 2012, Wolters Kluwer Law & Business; John Kaplan (law professor), Robert Weisberg, Guyora Binder, , Saephanh conceived a child with a woman, was imprisoned, and from prison wrote a letter soliciting another person to attack the woman to terminate the pregnancy. The letter was intercepted by a prison official before it was delivered. The court held that solicitation did not occur, but that "attempted solicitation" did, even though this was a doubly inchoate crime (i.e., neither the attack nor the communication actually occurred).
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