Published on: December 10, 2023 at 00:59 IST
Court: United States Court of Appeals
Citation: The People v. Marc Lynds Reid II
United States Court of Appeals (California Circuit) has held that “Rule of Lenity” requires a court to resolve statutory ambiguity in a criminal statute in favour of the accused, or to strictly construe the statute against the State. It is held that where the Legislature has manifested its intention, courts may not manufacture ambiguity in order to defeat that intent.
“[T]he ‘touchstone’ of the rule of lenity ‘is statutory ambiguity.’ [Citation.]” (Bifulco v. United States 447 US 381 (1980), 387, 100 S.Ct. 2247, 65 L.Ed.2d 205.) “‘the rule … applies only if the court can do no more than guess what the legislative body intended; there must be an egregious ambiguity and uncertainty to justify invoking the rule.’” (People v. Avery (2002) 27 Cat. 4th 49, 58, 115 Cal. Rptr.2d 403, 38 P.3d 1.) “Where the Legislature has manifested its intention, courts may not manufacture ambiguity in order to defeat that intent.” (Bifulco v. United States supra, at p. 387, 100 S.Ct. 2247.) Additionally, “ambiguities are not interpreted in the defendant’s favor if such an interpretation would provide an absurd result, or a result inconsistent with apparent legislative intent. (People v. Cruz (1996) 13 Cal. 4th 764, 783, 55 Cal. Rptr. 2D 117 P. 2d 731.)”
Drafted By Abhijit Mishra