State of Minnesota v. Terry Izeal Heggs

Summary

The Minnesota Court of Appeals reversed Terry Izeal Heggs’s conviction for knowingly failing to register as a predatory offender. The court held that the state did not prove beyond a reasonable doubt that Heggs knowingly violated the registration statute by listing an address as his workplace address without separately identifying it as a secondary address. The court concluded that a rational hypothesis consistent with innocence remained because Heggs may have believed that providing the address once satisfied the statute.

Holdings

1. The plain language of Minn. Stat. § 243.166, subd. 4a(a), does not expressly require a registrant to provide an address separately or multiple times when the address responds to more than one statutory category, nor does it expressly require the registrant to identify the applicable category or categories.
2. The state did not prove beyond a reasonable doubt that Heggs knowingly violated the predatory-offender-registration statute by failing to specify that his workplace address was also his secondary address.

Questions Presented

1. Whether the state proved beyond a reasonable doubt that Heggs failed to register a secondary address by providing an address that was both his workplace address and his secondary address without separately specifying that it was also a secondary address.
2. Whether the state proved beyond a reasonable doubt that Heggs knowingly violated the predatory-offender-registration statute.

Disposition

reversed