- Lambert v. California
Infobox SCOTUS case
Litigants = Lambert v. California
ArgueDate = April 3
ArgueYear = 1957
ReargueDateA = October 16
ReargueDateB = 17
ReargueYear = 1957
DecideDate = December 16
DecideYear = 1957
FullName = Lambert v. California
USVol = 355
USPage = 225
OralArgument = http://www.audiocasefiles.com/cases/detail/case/8648/
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.
SCOTUS = 1957-1958
Majority = Douglas
JoinMajority = Warren, Black, Clark, Brennan
Dissent = Burton
Dissent2 = Frankfurter
JoinDissent2 = Harlan, Whittaker
"Lambert v. California", 355 U.S. 225 (1957), was a
United States Supreme Courtcase regarding whether ignorance of the law can be used as a defense.
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 processunder the Fourteenth Amendment.cite book |title=Criminal Law |last=Bonnie |first=Richard J. |authorlink= |coauthors=Coughlin, Anne M. |year=1997 |publisher=The Foundation Press |location=Westbury, NY |isbn=1566624487 |pages=159–161 ]
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:
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 Codeaddresses this issue in Section 2.04 which echos the words of Justice Douglas.
List of United States Supreme Court cases, volume 355
*cite journal |last=Booke |first=A. F., II |authorlink= |coauthors= |year=1992 |month= |title=When Ignorance of the Law Became an Excuse: "Lambert" and Its Progeny |journal=American Journal of Criminal Law |volume=19 |issue=2 |pages=279–312 |issn=00922315 |url= |accessdate= |quote=
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