Tuesday, September 16, 2008

People v. Navarro (a.k.a. steal wood beams)

People v. Navarro
Appellate Department, Los Angeles County Superior Court, 1979.
99 Cal.App.3d Supp. 1, 160 Cal.Rptr. 692.

Judge Dowds delivered opinion

Facts:
  • Defendant was charged with stealing four wooden beams from a construction site
  • Jury could have found either
  • the beams had been abandoned as worthless and owner would not object to def. taking them
  • beams had substantial value, were not abandoned, and he had no right to take them
Issue:
Whether a good faith but unreasonable mistake is a defense to a charge?

Holding: Yes. Only reasonable mistakes removes liability from gen. intent. crimes. For specific intent crimes, still has to be good faith, reasonable or unreasonable.

Reasoning:
  • Specific intent is negated by good faith
  • Mistake of reasonable/unreasonableness doesn't matter
Judgment: Reversed

Rule:
Mistake of fact

3 comments:

Dr. A said...

When I read the title, my brain said "steel wood beams. Is this some crazy patent about composite building materials?" I haven't had my coffee yet, apparently.

Christie said...

Imagine operating on no coffee. I think I'm going to have to become a drinker to make it through this first semester.

Amber said...

I thought it said "steel wool beams."

I don't know if becoming a drinker is the right strategy. You sure you don't like coffee? I've heard it actually helps. Or maybe some of that cocaine (the energy drink, of course).