In People v. Mead (1904) 145 Cal. 500, a defendant was convicted of violating a criminal statute that made it a felony for a man to permit his wife to be placed at, or remain in, a house of prostitution. The defendant contended the court erred by denying his motion to arrest the judgment. The motion was made on the grounds that the statute did not make it a crime for a man to allow his wife to remain at a house of prostitution for a lawful purpose, such as to work as a cook or seamstress. The defendant argued no crime was stated because the accusatory pleading did not allege "the wife was left in the house of prostitution with the intention on the part of the husband that she should herself act as a prostitute." ( Id. at p. 503.) The information did, however, allege that the defendant left his wife at the house of prostitution "willfully, unlawfully and feloniously." (Id. at p. 502.) The California Supreme Court held a person of common understanding would construe these words to "exclude an act which by law was innocent." (Mead, 145 Cal. at p. 503.)