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Name: People v. Meneses
Case #: A113017
Court: CA Court of Appeal
District 1 DCA
Division: 4
Opinion Date: 08/19/2008

Court did not err by rejecting mistake of law and fact instructions where appellant claimed he did not know he was doing anything wrong. Appellant was convicted of multiple crimes arising out of a scheme to defraud insurance companies. On appeal, he argued that the trial court should have sua sponte instructed the jury on mistake of law and mistake of fact as defenses as there was evidence that appellant “did not think he did anything wrong.” The appellate court rejected the argument. Appellant’s claim that he didn’t know he was doing anything wrong does not provide a cognizable defense to the offenses. Ignorance of the law is not a defense. Further, the trial court had no duty to instruct on mistake of fact because the defense was contrary to appellant’s position at trial and was unsupported by the evidence.
Trial court had no sua sponte to instruct that the jury had to determine if single or multiple conspiracies existed. Appellant also argued that the trial court had a sua sponte duty to instruct the jury to determine if there were multiple conspiracies as charged, or a single all-inclusive conspiracy. The appellate court held that the trial court is required to instruct the jury to determine whether a single conspiracy or multiple conspiracies exist when there is evidence to support alternative findings. However, here the evidence did not support a finding that there was one overall conspiracy. The conspiracies were distinct and disconnected, and not part of an all-inclusive combination directed to a single unlawful end.