## Facts

- Neva B. Snyder was charged with possessing a concealable firearm as a convicted felon under California Penal Code § 12021(a).
- The charge was based on Snyder’s 1973 conviction for sale of marijuana, treated as a felony conviction.
- Snyder’s 1973 conviction resulted from a plea bargain not involving incarceration; Snyder asserted her attorney advised her she was pleading to a misdemeanor.
- After the 1973 conviction, Snyder acted on the belief she was not a felon, including registering to vote and voting.
- On an earlier occasion, police found a gun in Snyder’s home but did not charge her after determining it was registered to her husband.
- At trial on the § 12021 charge, Snyder sought to introduce evidence that she mistakenly believed her prior conviction was a misdemeanor and requested jury instructions requiring the prosecution to prove she knew she was a felon.
- The trial court excluded the proposed mistake evidence and refused the requested instructions; Snyder was convicted.

## Issues

1. Whether Penal Code § 12021(a) requires proof that a defendant knew of, or correctly understood, their status as a convicted felon.
2. Whether a defendant’s mistaken belief that a prior conviction was a misdemeanor is a defense to a felon-in-possession charge under § 12021(a).

## Decision

- The Supreme Court of California affirmed the judgment and upheld Snyder’s conviction.
- The court held § 12021(a) requires proof only that the defendant in fact suffered a felony conviction and owned or possessed a concealable firearm.
- The court held Snyder’s asserted belief that she was not a felon was a mistake of law and did not excuse liability.
- The court concluded the trial court did not err by excluding the mistake evidence or by declining instructions requiring knowledge of felony status as an element.

## Legal Principles

- The elements of Penal Code § 12021(a) are: (1) a felony conviction, and (2) ownership, possession, custody, or control of a concealable firearm.
- Section 12021(a) is a general-intent offense; no specific intent beyond intent to commit the prohibited act of possession is required.
- Ignorance or mistake of law is not a defense unless the statute makes knowledge a required element; § 12021(a) does not.
- A misunderstanding about whether a prior conviction is legally classified as a felony is treated as a mistake of law, not a mistake of fact negating mens rea.
- Persons are presumed to know the law and the legal consequences of a felony conviction, including firearm disability.

## Conclusion

The court held that felon-in-possession liability under Penal Code § 12021(a) turns on actual felony status and possession of a concealable firearm, not on the defendant’s subjective understanding of being a felon; a claimed misbelief about felony status is not a defense.


People v. Snyder, 32 Cal. 3d 590, 652 P.2d 42 (Cal. 1982)