Numerous Warren Court decisions have had substantial impacts on criminal procedure. Lambert v. California was one case that had the potential to make such an impact—but never did. This article will explain the case, as well as the differing interpretations associated with it. It will further explain how the narrow application of Lambert by the courts prevented it from having any farreaching effects. Finally, it will describe how it could have limited criminal liability enough to perhaps have mitigated the mass incarceration wave that would follow in its wake.