Constitutional Law – Due Process -Knowledge of the Law Required for Conviction Under Criminal Registration Ordinance

Defendant-appellant was charged with violation of a Los Angeles municipal ordinance which required all persons convicted of a felony in California, or of a crime committed elsewhere which would have been punishable as a felony in California, subsequent to January 1, 1921, to register with the Chief of Police upon remaining in the city longer than five days, or upon making more than five visits to the city within a thirty-day period. At the time of her arrest, appellant had been a resident of Los Angeles for seven years. Within that period she had been convicted (in Los Angeles) of forgery, a felony in California, and had subsequently failed to register as required. At her jury trial appellant asserted that the application of the ordinance to her was a denial of due process of law guaranteed by the Fourteenth Amendment to the Constitution of the United States, but was convicted, fined $250, and placed on probation for three years. Her motion for arrest of judgment and new trial was denied and the judgment affirmed on appeal by the Appellate Department of the Superior Court. On appeal to the United States Supreme Court, held, reversed, four justices dissenting. In the absence of actual knowledge or proof of facts sufficient to establish probable knowledge of the duty imposed by the ordinance, the conviction of appellant violated the due process requirement of the Fourteenth Amendment. Lambert v. California, 355 U.S. 225 (1957).