People v. Marrero, 69 N.Y.2d 382 (1987)

A defendant’s mistaken belief that a statute permitted their conduct is not a valid defense to a criminal charge under Penal Law § 15.20(2)(a); the statute itself must authorize the conduct.

Summary

The New York Court of Appeals addressed whether a defendant could claim a mistake of law defense under Penal Law § 15.20(2)(a) for carrying an unlicensed firearm based on his belief that he qualified as a peace officer under the statute. The court held that a mistake of law defense is only available if the statute actually permitted the conduct, not merely if the defendant believed it did. This decision reinforces the principle that ignorance of the law is no excuse, except in very limited circumstances explicitly outlined by statute, and emphasizes the importance of clear statutory interpretation in criminal defense.

Facts

The defendant, a federal corrections officer, was arrested and charged with criminal possession of a weapon for carrying a loaded, unlicensed firearm. He argued that he believed his conduct was legal because he interpreted Criminal Procedure Law (CPL) § 2.10(25) as defining “peace officer” broadly enough to include federal corrections officers, thereby exempting him from the licensing requirement under Penal Law § 265.20(a)(1)(a). The trial court initially dismissed the indictment, agreeing with the defendant’s interpretation. However, the Appellate Division reversed, reinstating the indictment.

Procedural History

1. The trial court dismissed the indictment.
2. The Appellate Division reversed and reinstated the indictment.
3. Defendant’s appeal to the Court of Appeals was dismissed.
4. The defendant was convicted at trial, and the Appellate Division affirmed the conviction.
5. This appeal to the New York Court of Appeals followed.

Issue(s)

Whether a defendant’s mistaken belief that a statute permitted his conduct constitutes a valid defense under Penal Law § 15.20(2)(a), or whether the statute must actually permit the conduct for the defense to apply.

Holding

No, because the defense under Penal Law § 15.20(2)(a) requires that the statute, in fact, authorize the conduct, not merely that the defendant mistakenly believed it did.

Court’s Reasoning

The court reasoned that Penal Law § 15.20(2)(a) provides a very narrow exception to the general rule that ignorance of the law is no excuse. The court emphasized the importance of adhering to the plain language of the statute. “To relieve one from criminal liability based on a mistaken interpretation of a statute, the defendant must demonstrate that the statute, as officially interpreted, actually permitted the conduct in question.” The court rejected the defendant’s argument that his good-faith belief in the legality of his actions, based on his interpretation of the relevant statutes, was sufficient to invoke the defense.

The court distinguished the New York statute from the Model Penal Code, which provides a defense when a defendant reasonably relies on a statute later determined to be invalid or erroneous. New York’s statute does not contain this provision. The court also stated that permitting a mistake of law defense based on a defendant’s subjective interpretation of a statute would create an “exception that would swallow the rule,” encouraging mistakes about the law and allowing wrongminded individuals to contrive defenses. The dissent argued that the majority’s interpretation was contrary to the statute’s plain wording and the legislative intent to reform the common-law rule prohibiting a mistake of law defense, emphasizing the importance of subjective moral blameworthiness in criminal law. The dissent asserted that the defendant’s good-faith reliance on a reasonable interpretation of the statute should constitute a valid defense.