Simms v. District of Columbia
District of Columbia Court of Appeals
612 A.2d 215 (1992)
Relevant factsFree
Simms (defendant) was found placing boards and standing near a jack under a stolen Volkswagen Jetta that had sat with broken windows in the same spot for weeks, and though a companion testified she believed the car was abandoned and Simms was helping her find replacement parts, Simms himself testified he didn't actually know whether the car was stolen or abandoned but suspected it was abandoned; a hearing commissioner found him liable for vehicle tampering.
IssueFree
Whether, for a general-intent crime, a mistake-of-fact defense applies only if the defendant's mistake was both honest and reasonable.