Lambert v. California
Supreme Court of the United States · Decided December 16, 1957 · Core case
Full citation
Lambert v. California, 355 U.S. 225 (1957).
VerifiedQuotes, pinpoints and citation checked word for word against the opinion; facts checked against the opinion before publication. October 20, 2026.
Lambert
residentappellant
California
stateappellee
Brief
Facts
Section 52.38 (a) of the Los Angeles Municipal Code defined a convicted person as anyone convicted after January 1, 1921, of an offense punishable as a felony in California, or convicted elsewhere of an offense that would be so punishable. Section 52.39 made it unlawful for any convicted person to be or remain in Los Angeles for more than five days without registering and furnishing information to the Chief of Police. Section 52.43 (b) made failure to register a continuing offense, with each day counting as a separate violation. No element of willfulness was in the ordinance's terms or read into it by the California court. Lambert was arrested on suspicion of another offense and charged with violating the registration ordinance. At the time of her arrest, she had lived in Los Angeles for over seven years. During that period, she had been convicted in Los Angeles of forgery, an offense California punished as a felony. She had not registered under the Municipal Code. Lambert offered proof that she had no actual knowledge of the requirement that she register, but the proof was refused, so the Supreme Court had to assume she did not know. Her failure to register was unaccompanied by any activity, mere presence in the city being the test, and circumstances that might alert someone to inquire about registering were completely lacking. Once aware of the requirement, she received no opportunity to comply and avoid penalties.
Issue
Does a municipal registration ordinance that punishes a person for wholly passive failure to register violate Fourteenth Amendment due process when applied to someone who had no actual knowledge of the duty to register and where no showing was made of the probability of such knowledge?
Holding
The registration provisions of the Los Angeles Municipal Code, as sought to be applied to Lambert, violated the Due Process requirement of the Fourteenth Amendment. Her conduct was wholly passive, the Court had to assume she had no actual knowledge of her duty to register, and no showing was made of the probability of such knowledge.
IRAC
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