People v. Snyder
32 Cal. 3d 590, 652 P.2d 42, 186 Cal. Rptr. 485 (1982)
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Rule of Law:
A defendant's mistaken belief regarding their legal status as a convicted felon constitutes a mistake of law, not a mistake of fact, and is therefore not a valid defense to a charge of being a felon in possession of a firearm.
Facts:
- In 1973, Neva Snyder was convicted of selling marijuana, which is a felony, following a plea bargain.
- At the time of her plea, Snyder's attorney advised her that she was pleading guilty to a misdemeanor.
- Snyder did not serve any jail or prison time for the marijuana conviction.
- Based on her belief that she was not a felon, Snyder later registered to vote and voted.
- On a prior occasion, police found a gun in Snyder's home but did not charge her after determining it was registered to her husband.
- Police subsequently found Snyder in possession of a concealable firearm, which led to the current charges.
Procedural Posture:
- Neva Snyder was charged in a California trial court with possession of a concealable firearm by a convicted felon.
- At trial, the court excluded Snyder's proffered evidence that she mistakenly believed her prior conviction was a misdemeanor.
- The trial court also refused Snyder's proposed jury instructions requiring knowledge of her felony status as an element of the offense.
- Snyder was convicted of the charge.
- Snyder appealed the judgment of conviction to the Supreme Court of California.
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Issue:
Does a defendant's mistaken belief that their prior conviction was a misdemeanor, rather than a felony, constitute a valid defense to a charge of being a felon in possession of a firearm under Penal Code § 12021?
Opinions:
Majority - Richardson, J.
No. A defendant's mistaken belief about their legal status as a convicted felon is a mistake of law and does not constitute a defense to a felon-in-possession charge. The crime requires only a general intent to possess the firearm, not specific knowledge of one's legal status as a felon. The court distinguished between a mistake of fact, which can be a defense, and a mistake of law, for which ignorance is no excuse. Snyder was presumed to know the law, which includes both the prohibition on felons possessing firearms and the fact that her prior conviction for selling marijuana was, as a matter of law, a felony. This holding is consistent with federal court interpretations of a similar statute, which have uniformly found that a defendant's knowledge of their felon status is not an element of the offense.
Dissenting - Broussard, J.
Yes. An honest and reasonable mistaken belief as to one's felony status should negate the requisite general criminal intent and serve as a valid defense. The dissent argues that the general intent requirement (mens rea) should apply to both elements of the offense: possession of the firearm and the status of being a felon. To impose strict liability on the status element contradicts the principle that a wrongful intent is a necessary element of every crime unless expressly excluded. The dissent contends that Snyder's mistake about her legal status, particularly when based on the advice of her attorney, should be treated as a mistake of fact that negates a 'guilty mind,' and the trial court erred by refusing to let the jury consider this evidence.
Analysis:
This decision solidifies the strict application of the 'ignorance of the law is no excuse' maxim to status-based offenses. It establishes a clear precedent in California that a mistake regarding one's own legal status is a non-defensible mistake of law, distinguishing it from potentially defensible mistakes about external facts (e.g., a victim's age). By doing so, the court effectively makes the 'felon' element of the felon-in-possession crime a strict liability element; the prosecution need only prove the fact of the prior conviction, not the defendant's awareness of its legal classification. This ruling significantly limits the defenses available to individuals charged under this statute and similar status-based laws.
