Lambert v. California
Encyclopedia
Lambert v. California, 355 U.S. 225
(1957), was a United States Supreme Court case regarding the acceptability of ignorance of the law as an excuse for a crime. The court held that in order to be punished, there must be a probability that the accused party had knowledge of the law before committing the crime.
, a felony in California
. She was unaware that a Los Angeles
city ordinance required that she, being a felon, register if she remained in the city for more than five days. The ordinance stipulated that she, as a convicted criminal, could be fined $500 and sentenced to up to six months in jail for every day she remained in the city after the five day limit. 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
.
, who delivered the majority opinion for the court, wrote:
However, the court did not overturn the right of states and municipalities to force occupants to register for a given purpose. The court held that because the ordinance that forced ex-felons to register was not accompanied by any action, nor were there circumstances that would lead an ex-felon to be aware of his or her duty to register, the ordinance was unconstitutional. The Justice continued:
, the degree of legal culpability that arises from the motivation of a criminal.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1957), was a United States Supreme Court case regarding the acceptability of ignorance of the law as an excuse for a crime. The court held that in order to be punished, there must be a probability that the accused party had knowledge of the law before committing the crime.
Circumstances
Ms. Lambert had previously been convicted of forgeryForgery
Forgery is the process of making, adapting, or imitating objects, statistics, or documents with the intent to deceive. Copies, studio replicas, and reproductions are not considered forgeries, though they may later become forgeries through knowing and willful misrepresentations. Forging money or...
, a felony in California
California
California is a state located on the West Coast of the United States. It is by far the most populous U.S. state, and the third-largest by land area...
. She was unaware that a Los Angeles
Los Ángeles
Los Ángeles is the capital of the province of Biobío, in the commune of the same name, in Region VIII , in the center-south of Chile. It is located between the Laja and Biobío rivers. The population is 123,445 inhabitants...
city ordinance required that she, being a felon, register if she remained in the city for more than five days. The ordinance stipulated that she, as a convicted criminal, could be fined $500 and sentenced to up to six months in jail for every day she remained in the city after the five day limit. 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
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
under the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
.
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. Justice William DouglasWilliam O. Douglas
William Orville Douglas was an Associate Justice of the United States Supreme Court. With a term lasting 36 years and 209 days, he is the longest-serving justice in the history of the Supreme Court...
, who delivered the majority opinion for the court, wrote:
However, the court did not overturn the right of states and municipalities to force occupants to register for a given purpose. The court held that because the ordinance that forced ex-felons to register was not accompanied by any action, nor were there circumstances that would lead an ex-felon to be aware of his or her duty to register, the ordinance was unconstitutional. The Justice continued:
Significance
This case is an exception to the legal principle ignorantia legis non excusat — that the ignorance of the law is not a suitable excuse for breaking it. Because it deals with the motives (or lack thereof) for committing a crime, it addresses mens reaMens rea
Mens rea is Latin for "guilty mind". In criminal law, it is viewed as one of the necessary elements of a crime. The standard common law test of criminal liability is usually expressed in the Latin phrase, actus non facit reum nisi mens sit rea, which means "the act does not make a person guilty...
, the degree of legal culpability that arises from the motivation of a criminal.
