In Lambert v. People of the State of California, 355 U.S. 225 (1957), the defendant was convicted of violating a provision of the Los Angeles Municipal Code ("the Code") requiring convicted felons to register as such with the municipality upon remaining in Los Angeles for more than five days. The defendant had resided in Los Angeles for seven years during which she had been convicted of forgery, an offense punishable as a felony, but failed to register herself as a convicted felon. She was subsequently charged and convicted of violating the Code. On appeal, the Court held that applying the registration provision of the Code to the defendant violated her right to due process under the Fourteenth Amendment to the United States Constitution. 355 U.S. at 226 - 27. In so holding, the Court reasoned that a violation of the Code "is unaccompanied by any activity whatever, mere presence in the city being the test. Moreover, circumstances which might move one to inquire as to the necessity of registration are completely lacking. . . . We believe that actual knowledge of the duty to register or proof of the probability of such knowledge and subsequent failure to comply are necessary before a conviction under the Code can stand. As Holmes wrote in The Common Law, "A law which punished conduct which would not be blameworthy in the average member of the community would be too severe for that community to bear." Its severity lies in the absence of an opportunity either to avoid the consequences of the law or to defend any prosecution brought under it. Where a person did not know of the duty to register and where there was no proof of the probability of such knowledge, he may not be convicted consistently with due process. Were it otherwise, the evil would be as great as it is when the law is printed too fine to read or in a language foreign to the community." Id. at 229-30 . The holding in Lambert is limited. See: (1) U.S. v. Freed, 401 U.S. 601, 608-09, 91 S. Ct. 1112, 28 L. Ed. 2d 356 (1971) (declining to apply Lambert to possession of unregistered hand grenades under National Firearms Act); (2) U.S. v. Mitchell, 209 F.3d 319, 323-24 (4th Cir. 2000) (recognizing that "Lambert's reach has been exceedingly limited" and declining to apply Lambert to statute making it unlawful for persons previously convicted of misdemeanor domestic violence to possess firearms or silencers); (3) U.S. v. Meade, 175 F.3d 215, 225-26 (1st Cir. 1999) (noting United States Supreme Court has resisted efforts to extend Lambert and declining to apply Lambert to same statute at issue in Mitchell); (4) U.S. v. Horton, 503 F.2d 810, 813 (7th Cir. 1974) (acknowledging Freed Court's limitation on Lambert and holding Lambert inapplicable to statutory provision making it illegal for defendant to receive firearms in commerce as convicted felon); (5) U.S. v. Milheron, 231 F.Supp.2d 376, 379 (D. Me. 2002) (holding Lambert exception to rule that ignorance of law does not excuse criminal behavior inapplicable to defendant's possession of firearm after having been committed to mental institution).