State v. Woods

Supreme Court of Vermont
1935 Vt. LEXIS 184, 179 A. 1, 107 Vt. 354 (1935)

ELI5:

Sections

Rule of Law:

A defendant's honest belief in the validity of a foreign divorce and subsequent marriage constitutes a mistake of law, which is not a valid defense to a criminal charge of illicit cohabitation.

Facts:

In the summer of 1933, the respondent (a single woman) traveled to Reno, Nevada with Leo Shufelt (a man married to a woman living in Vermont) and a third companion.
Shufelt instituted divorce proceedings in Nevada against his wife.
Shufelt's wife, remaining in Vermont, was served with process but did not appear in the Nevada proceedings or go to Nevada.
A Nevada court granted Shufelt a divorce decree.
Immediately following the decree, the respondent and Shufelt were married in Reno by the judge who granted the divorce.
The respondent and Shufelt returned to Lowell, Vermont.
Relying on the Nevada marriage, the respondent and Shufelt lived together and entered into marital relations in Vermont.

Procedural Posture:

The State prosecuted the respondent in the Orleans County Court for violating the Blanket Act.
The trial court ruled as a matter of law that the Nevada divorce was invalid.
The jury convicted the respondent.
The respondent filed exceptions (appealed) to the Supreme Court of Vermont, challenging the trial court's jury instructions regarding her intent and belief in the marriage's validity.

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Issue:

Is a defendant's honest but mistaken belief that a foreign divorce decree and subsequent marriage were legally valid a defense to a prosecution for illicit sexual cohabitation?

Opinions:

Majority - Justice Buttles

No, a defendant cannot use a mistake of law regarding the validity of a marriage as a defense to charges of illicit cohabitation. Justice Buttles reasons that the respondent was fully aware of the facts—specifically, that she was in Reno and Shufelt's wife remained in Vermont. Her error lay in misunderstanding the legal effect that the Nevada decree would have in Vermont, which constitutes a mistake of law rather than a mistake of fact. The court applies the established maxim 'Ignorantia legis non excusat' (ignorance of the law excuses no one). While the court acknowledges that mistake of fact can sometimes be a defense (citing State v. Audette), mistake of law cannot. Public policy requires this strict interpretation; otherwise, individuals could circumvent Vermont's marriage and divorce laws by obtaining invalid foreign divorces and claiming ignorance of their invalidity to avoid prosecution for sexual offenses.

Analysis:

This case illustrates the rigid application of the 'mistake of law' doctrine in criminal law, particularly regarding strict liability public welfare offenses or moral statutes. The court distinguishes between not knowing a fact (e.g., 'I thought my spouse was dead') and not knowing the law (e.g., 'I thought this divorce paper was legal here'). By ruling that the intent requirement ('illicit intention') is satisfied merely by the intent to do the prohibited act (sleeping together), regardless of the defendant's belief in its legality, the court reinforces state sovereignty over marriage laws and closes a loophole that would allow couples to utilize 'divorce mills' in other states to bypass local laws.

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