People v. Hall, 213 Cal. Rptr. 3d 561

LaQuincy Hall was convicted of possession of cocaine base for sale and placed on three years' probation with conditions barring ownership, possession, custody, or control of firearms and of illegal drugs/paraphernalia without a prescription.
Hall did not object to these conditions in the trial court but raised a facial vagueness challenge on appeal, arguing the conditions fail to specify the mens rea required for violation.
The Court of Appeal rejected Hall's challenge, holding that possessory probation conditions implicitly require knowing possession and therefore need not be modified.
The Supreme Court granted review to resolve conflicting appellate authority on whether possessory probation conditions must explicitly state a knowledge requirement.
The Supreme Court concluded that possessory probation conditions are not unconstitutionally vague because California case law and general presumptions supply an implicit knowledge/willfulness requirement; adding the word "knowingly" would not change the substance of the conditions.
The Court affirmed the Court of Appeal and disapproved conflicting Court of Appeal decisions to the extent they required an express scienter term.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether probation conditions banning possession of firearms and illegal drugs are unconstitutionally vague because they do not state the required mens rea	Hall: Conditions must explicitly require "knowing" possession to afford fair warning	People: Conditions implicitly include a knowledge requirement via case law; no textual modification required	Held: Conditions are not void for vagueness; knowledge/willfulness is implicit and required to revoke probation
Whether Sheena K. requires textual modification to insert mens rea language	Hall: Sheena K. supports modifying vague probation terms	People: Sheena K. is distinguishable; it addressed a different vagueness problem (undefined category of prohibited associates)	Held: Sheena K. does not compel insertion of "knowingly"; court may, but is not required, to spell out scienter when imposing conditions

Connally v. General Const. Co., 269 U.S. 385 (U.S. 1926) (void-for-vagueness fair-warning principle)
Staples v. United States, 511 U.S. 600 (U.S. 1994) (presumption that scienter is required for criminal statutes)
In re Sheena K., 40 Cal.4th 875 (Cal. 2007) (modification for vague probation condition prohibiting association with persons "disapproved of" by probation)
People v. Jorge M., 23 Cal.4th 866 (Cal. 2000) (probation conditions generally presumed to require willfulness unless excluded)
People ex rel. Gallo v. Acuna, 14 Cal.4th 1090 (Cal. 1997) (external sources may make vague terms sufficiently definite)
People v. Martin, 25 Cal.4th 1180 (Cal. 2001) (possession of controlled substances requires knowledge of presence and restricted character)
People v. King, 38 Cal.4th 617 (Cal. 2006) (possession of weapons requires knowledge)
People v. Leiva, 56 Cal.4th 498 (Cal. 2013) (revocation typically requires proof that violation was willful)