April 1, 2011
The holiday has been celebrated in the Western world for over 600 years, and has led to a wide variety of pranks and, of course, misunderstandings.
Given its history, it would seem only natural that April Fools’ would find its way into the legal world.
And so it has in a variety of forms.
Some people simply take a joke too far, and then have to face the legal consequences.
In re G.W. deals with a denial of admission to the New Hampshire state bar. The decision by the state supreme court found that the applicant failed the moral fitness test, in part, because of his explanation of a “reckless conduct” conviction. The applicant’s explanation was that it was an April Fools’ joke in which the applicant “pretended to be a robber” at a convenience store.
In People v. Crittle, the defendant was convicted of intended armed robbery. Probably intoxicated at the time, he held up a grocery store with a toy gun, and returned the money shortly after he received it from the cashier, saying it was just an April Fool’s joke. While the conviction was eventually overturned by the state supreme court, the joke probably wasn’t worth the trouble.
Of course, sometimes April Fools’ is used as an excuse for doing something that you later regret (or get caught for).
In State v. Hicks, the defendant claimed that he made a confession about his involvement in a robbery in order to play an April Fools’ joke on the police. And because he said that he was an alcoholic and believed that if he told them what they wanted to hear, they would let him go home where he could continue drinking.
A defendant in U.S. v. Marchant failed to convince federal prosecutors that he received child pornography only as an April Fools’ Day joke, as though it would have made a difference if that were true.
In Ford v. Institutional Division, an inmate assaulted several other inmates and attempted to escape, and later referred to the incident as “an innocent ‘April Fools’ Day Joke.’”
In rare cases, someone will use April Fools’ Day as an excuse to indulge in his more violent tendencies.
In State v. Stone, the defendant was convicted of intent to inflict serious injury because of his idea of an April Fools’ joke: he slashed the tires of a female acquaintance’s car and red spray-painted the front door. After he did it, he called her and said “April Fools’, [expletive], I hope you enjoy your new tires.”
And there have certainly been many more April Fools’ cases that have gone under the radar.
The point here is that while everyone loves a good April Fools’ joke, the excuse seldom provides legal immunity to otherwise unlawful behavior.