Lambert v. California Case Brief

Why is the case important?

Defendant Lambert was convicted for violating a California ordinance that requires any convicted person who remains in California for the specified period to register with the State. Defendant offered proof that she had no actual knowledge of the ordinance, however the proof was refused.

Facts of the case

Under Los Angeles Municipal Code Section 52.39, no convicted felon could stay in the city for more than five days without registering. Lambert, a convicted felon, stayed in Los Angeles for seven years without registering and was convicted of violating the ordinance. On appeal, she argued that due process under the Fourteenth Amendment required the ordinance to include some mental state element, and she was not aware of it.

Question

Are an individual’s Due Process rights violated where a registration act is 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?

Answer

Yes. Judgment reversed.
Imposition of this registration law on an individual who has no actual knowledge of a duty to register and where no showing is made of the probability of such knowledge is a violation of due process.

Conclusion

The U.S. Supreme Court held that the ordinance violated the due process requirement of the Fourteenth Amendment when it was applied to a person who had no actual knowledge of her duty to register and where no showing was made of the probability of such knowledge.

  • Case Brief: 1957
  • Appellant: Lambert
  • Appellee: California
  • Decided by: Warren Court

Citation: 355 US 225 (1957)
Argued: Apr 3, 1957
ReArgued: Oct 16 – 17, 1957
Decided: Dec 16, 1957