Lambert v. California
Docket: 47
Court: Supreme Court of the United States; January 27, 1958; Federal Supreme Court; Federal Appellate Court
Section 52.38(a) of the Los Angeles Municipal Code defines a "convicted person" as anyone convicted of a felony in California or an equivalent offense elsewhere since January 1, 1921. Section 52.39 prohibits such individuals from remaining in Los Angeles for more than five days without registering, and requires those with residences outside the city to register if visiting five times in 30 days. Failure to register constitutes a continuing offense. The appellant, arrested for another charge, had lived in Los Angeles for over seven years and had a prior felony conviction for forgery but had not registered. She claimed Section 52.39 violated her due process rights, but the trial court denied her objection, leading to a conviction and a $250 fine with three years of probation. After her constitutional challenge was again denied on appeal, the case reached the Supreme Court. The Court determined that the registration requirement, imposing criminal penalties, violates the Due Process Clause of the Fourteenth Amendment. It found that the ordinance lacks any requirement of willfulness for conviction and assumed the appellant had no actual knowledge of the registration obligation. The Court ruled that applying such a registration law to someone unaware of the requirement does not satisfy due process, particularly as the offense was merely passive in nature—failure to register—rather than an active commission of a crime. The principle that "ignorance of the law will not excuse" is established in legal doctrine, particularly in relation to local government police powers, which are limited by due process requirements, including the necessity of notice. Notice is critical in scenarios where individuals face penalties or property interests are affected, as demonstrated in cases like Mullane v. Central Hanover Trust Co. and Covey v. Town of Somers. While registration laws are prevalent and often related to business regulation, the ordinance in question is distinct because it penalizes mere presence in the city without any action taken by the individual. This lack of proactive inquiry into registration undermines due process, as the appellant was unaware of the registration requirement and was not afforded an opportunity to comply before facing criminal penalties. The ruling asserts that for a conviction under this ordinance to be valid, there must be actual knowledge of the registration duty or reasonable evidence of such knowledge. Punishing individuals without this awareness violates the principles of fair notice and due process. The decision was reversed, with a dissent from Justice Burton, who contended that the ordinance did not infringe upon the appellant's constitutional rights.