Facts
- Neva B. Snyder pleaded guilty in 1973 to sale of marijuana, a felony, and received no jail or prison sentence.
- Snyder claimed her attorney told her she was pleading to a misdemeanor, leading her to believe she was not a felon.
- Snyder later possessed a concealable firearm and was charged under Penal Code § 12021(a) (possession of a concealable firearm by a convicted felon).
- At trial, Snyder sought to introduce evidence of her belief that her prior conviction was a misdemeanor and requested jury instructions requiring proof she knew she was a felon.
- The trial court excluded the evidence and rejected the proposed instructions; Snyder was convicted.
Issues
- Whether a defendant’s mistaken belief that a prior conviction was a misdemeanor, rather than a felony, is a defense to Penal Code § 12021(a).
- Whether the prosecution must prove the defendant knew of her status as a convicted felon, making it error to exclude belief evidence and refuse knowledge-of-status instructions.
Decision
- The California Supreme Court affirmed the conviction.
- Penal Code § 12021(a) requires proof only that the defendant had a felony conviction and possessed (or had custody or control of) a concealable firearm.
- The statute does not require proof the defendant knew she was a felon.
- Snyder’s asserted misunderstanding about the legal classification of her prior conviction was not a defense.
- The trial court properly excluded the proffered belief evidence and refused jury instructions that would add a knowledge-of-status element.
Legal Principles
- Under Penal Code § 12021(a), the elements are (1) a felony conviction and (2) ownership, possession, custody, or control of a concealable firearm.
- The offense is one of general intent; no specific intent (including knowledge of felon status) is required beyond intent to commit the prohibited act of possession.
- A mistaken belief about one’s legal status as a felon is treated as a mistake of law and does not excuse liability where the statute does not make knowledge of status an element.
- Evidence and instructions aimed at negating a non-element (knowledge of felon status) are properly excluded or refused.
Conclusion
The court upheld Snyder’s felon-in-possession conviction, holding that Penal Code § 12021(a) imposes a general-intent prohibition and that a sincere misunderstanding— even if based on counsel’s advice—about whether a prior conviction is a felony is not a defense.