California v. Byers Case Brief

Facts of the Case

“The first count of a criminal complaint charged a motorist with violation of the California Vehicle Code’s provision against passing another vehicle without maintaining a safe distance, and the second count of the complaint charged him with failing to comply with the provisions of the “hit and run” statute, requiring the driver of a motor vehicle involved in an accident resulting in damage to any property to stop at the scene and give his name and address. Both charges arose out of the same accident, and the defendant’s demurrer to the second count, asserting violation of his privilege against self-incrimination, was overruled by a California Justice Court. The defendant then sought a writ of prohibition from the Superior Court of Mendocino County, California, to restrain prosecution of the second count. The Superior Court issued the writ, and the Supreme Court of California ultimately affirmed, holding that the privilege against self-incrimination was applicable to a motorist, such as the defendant, who reasonably believed that compliance with the statute would result in a substantial risk of self-incrimination. The California Supreme Court also held that in the case of such a motorist, the hit-and-run statute should be limited by a restriction preventing use in subsequent criminal prosecutions, arising from the motorist’s conduct, of information disclosed under the statute, and the fruits of such information, but the court concluded that it would be unfair to punish the defendant for failure to comply with the statute, since he could not have had knowledge that use restrictions would be imposed by the courts.”


“Does the term “willfully” in 18 USC section 924(a)(1)(D) require proof that the defendant knew that his conduct was unlawful and that he knew of the federal licensing requirement for dealing in firearms?”



Case Information

Citation: 402 US 424 (1971)
Argued: Dec 8, 1970
Decided: May 17, 1971
Case Brief: 1971