Spence
People v. Spence
Opinion
Opinion
Ramirez, J.
As is pertinent here, a jury convicted Francis Spence (Spence) of driving without a valid driver’s license. (Veh. Code, § 12500.) He was granted probation.
We granted transfer of this case to this court upon certification by the Appellate Division of the Superior Court of Riverside County to address the following question: May a defendant be convicted of driving with an invalid driver’s license in violation of section 12500 if he did not have actual knowledge that his license was suspended? (Cal. Rules of Court, rule 62.)
We conclude that he may, because section 12500 is a public welfare statute.
Facts
On January 30, 2001, Spence received a citation for a defective windshield or rear window. His driver’s license was suspended on June 10, 2001, for failure to appear as promised on a citation or for failure to appear after a court continuance. Notice of the suspension was sent to him on May 9, 2001, by certified letter, but the letter was returned unclaimed. The Vehicle Code mandates that drivers’ addresses be updated within 14 days of their moving to a new address. On November 22, 2001, when Spence was seen driving a vehicle, he did not have a valid…