Lambert v. California
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| Lambert v. California | ||||||
 Supreme Court of the United States |
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| Argued April 3, 1957 Reargued October 16–17, 1957 Decided December 16, 1957 |
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| Full case name | Lambert v. California | |||||
| Citations | 355 U.S. 225 (more) | |||||
| Argument | Oral argument | |||||
| Holding | ||||||
| When applied to a person who has no actual knowledge of his duty to register, and where no showing is made of the probability of such knowledge, this ordinance violates the Due Process Clause of the Fourteenth Amendment. | ||||||
| Court membership | ||||||
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| Case opinions | ||||||
| Majority | Douglas, joined by Warren, Black, Clark, Brennan | |||||
| Dissent | Burton | |||||
| Dissent | Frankfurter, joined by Harlan, Whittaker | |||||
Lambert v. California, 355 U.S. 225 (1957), was a United States Supreme Court case regarding whether ignorance of the law can be used as a defense.
Contents |
[edit] Circumstances
Ms. Lambert was convicted of forgery, a felony in Los Angeles. She was unaware that a Los Angeles city ordinance required that she register if she remained in the city for more than five days and that furthermore, another ordinance fined her $500 or up to 6 months in jail for each day she failed to register. Since she failed to register, when she was arrested on suspicion of committing another offense she was convicted for failure to register. As Lambert was not allowed to use her lack of knowledge as a defense, she was convicted, fined $250 and sentenced to three years probation. Lambert appealed her case, arguing that she had no knowledge that she had to register her name and that convicting her would deprive her of Due process under the Fourteenth Amendment.[1]
[edit] Decision
The Supreme Court reversed Lambert's conviction, holding that knowledge or probability of knowledge of a statute is required to convict someone of a notice offense. In an opinion by Justice Douglas, he wrote:
Where a person did not know of the duty to register and where there was no proof of the probability of such knowledge, he may not be convicted consistently with due process.[1]
[edit] Significance
This decision addresses the issue of the mental element of the crime, mens rea. The decision can be seen as an exception to the legal principle that ignorance of law does not excuse. However, there is a more fundamental concern expressed in this decision, and that is what are the mimimum conditions acceptable for imposing criminal liability? The Model Penal Code addresses this issue in Section 2.04 which echos the words of Justice Douglas.[1]
[edit] See also
[edit] References
- ^ a b c Bonnie, Richard J.; Coughlin, Anne M. (1997). Criminal Law. Westbury, NY: The Foundation Press. pp. 159–161. ISBN 1566624487.
[edit] Further reading
- Booke, A. F., II (1992). "When Ignorance of the Law Became an Excuse: Lambert and Its Progeny". American Journal of Criminal Law 19 (2): 279–312. ISSN 00922315.
