State v. Holloway

Summary

The Minnesota Supreme Court affirmed Christopher Lee Holloway’s convictions for third- and fourth-degree criminal sexual conduct involving a 14-year-old complainant. The court held that Minnesota’s limitation of the mistake-of-age defense did not violate substantive due process or equal protection. The court also held that the statutes were not strict-liability offenses because they required general intent to engage in sexual penetration or sexual contact.

Holdings

1. The challenged statutes do not violate substantive due process because a defendant has no fundamental constitutional right to assert a mistake-of-age defense in a statutory-rape or criminal-sexual-conduct prosecution, and limiting the defense for certain adults is rationally related to the legitimate objective of protecting children from sexual abuse and exploitation.
2. The challenged statutes do not violate equal protection under either the federal or Minnesota Constitution. Although defendants permitted and barred from asserting the defense are similarly situated, the age-based classification survives Minnesota's more stringent rational-basis test and therefore also survives federal rational-basis review.
3. Minnesota Statutes sections 609.344, subdivision 1(b), and 609.345, subdivision 1(b), do not impose strict liability. They require proof beyond a reasonable doubt that the defendant had the general intent to engage in sexual penetration or sexual contact, but they do not require proof that the defendant knew or had reason to know the complainant's age.

Questions Presented

1. Whether limiting the mistake-of-age defense in Minnesota Statutes sections 609.344, subdivision 1(b), and 609.345, subdivision 1(b), violates substantive due process under the federal or Minnesota Constitution.
2. Whether allowing the mistake-of-age defense for some defendants but not for defendants more than 120 months older than the complainant violates equal protection under the federal or Minnesota Constitution.
3. Whether the challenged criminal-sexual-conduct statutes impose strict liability by not requiring proof that the defendant knew the complainant's age.

Disposition

affirmed