People v. Marrero
Citation: 69 N.Y.2d 382 (1987) Court: New York Court of Appeals
Facts
Marrero was a federal corrections officer who was arrested in New York for carrying a loaded handgun without a permit. He argued that he was exempt from New York’s handgun laws under a statutory provision exempting “peace officers,” which he believed included federal corrections officers. His interpretation of the statute was incorrect. He sought to raise mistake of law as a defense.
Issue
May a defendant avoid criminal liability by arguing that he reasonably but mistakenly believed his conduct was lawful based on his own interpretation of a statute?
Holding
No. The New York Court of Appeals rejected Marrero’s mistake-of-law defense, holding that a defendant’s personal misreading or misunderstanding of a statute does not excuse criminal conduct.
Rule / Doctrine
Ignorance of the law is generally not a defense to a criminal charge. A defendant’s mistaken belief about the legal meaning of a statute does not negate mens rea unless the statute expressly provides for such a mistake-of-law defense. The narrow exception for reliance on official interpretations (e.g., an opinion from the Attorney General or a court ruling) did not apply here because Marrero relied solely on his own interpretation of the law.
Significance
People v. Marrero is a leading case illustrating the traditional rule that mistake of law — as distinguished from mistake of fact — is not a defense to crime. The case also demonstrates the limits of the mistake-of-law exception available under the Model Penal Code: reliance on one’s own reading of an ambiguous statute does not qualify as reliance on an “official statement” of the law sufficient to excuse criminal conduct.