State of Minnesota v. David Lee Haywood
886 N.W.2d 485
| Minn. | 2016Background
- Police found a Walther CP99 Compact CO2 air BB pistol (.177 caliber) in David Haywood’s glove compartment after arresting him on a no-contact-order violation.
- Haywood is a convicted felon; the State charged him under Minn. Stat. § 609.165, subd. 1b (possession of a firearm by an ineligible person).
- Haywood moved to dismiss arguing (1) the BB gun is not a “firearm” under § 609.165 and (2) the statute is unconstitutionally vague as applied; the district court denied both motions and the jury convicted Haywood.
- The Minnesota Court of Appeals affirmed, relying on State v. Seifert to interpret “firearm” broadly to include guns using compressed air.
- The Minnesota Supreme Court granted review and reversed: holding that under the plain, ordinary meaning of “firearm” (as requiring explosive or combustible propellant), an air-powered BB gun is not a “firearm” for § 609.165, and Haywood’s conviction was vacated.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an air-powered BB gun is a “firearm” under Minn. Stat. § 609.165 | Haywood: a “firearm” in ordinary meaning requires explosive/combustive propellant; CO2 BB gun uses compressed air and thus is not a firearm | State: Seifert and subsequent authority support a broad definition including guns using compressed air; Legislature’s inaction implies acceptance | Court: Plain meaning of “firearm” requires explosive force; air-powered BB gun is not a firearm under § 609.165 — conviction vacated |
| Whether § 609.165 is unconstitutionally vague as applied to Haywood | Haywood: statute failed to give fair notice that possessing a CO2 BB gun would be prohibited | State: prior case law provides a sufficiently definite meaning; not vague as applied | Court: Did not reach vagueness claim because it resolved the case on plain-language ground |
Key Cases Cited
- State v. Seifert, 256 N.W.2d 87 (Minn. 1977) (interpreted “firearm” broadly in context of dangerous-weapon definition)
- State v. Newman, 538 N.W.2d 476 (Minn. Ct. App. 1995) (applied Seifert’s reasoning to a drive-by shooting statute)
- State v. Fleming, 724 N.W.2d 537 (Minn. Ct. App. 2006) (applied Seifert to possession prohibition for persons convicted of violent crimes)
- Morris v. State, 765 N.W.2d 78 (Minn. 2009) (commentary on judicial restraint and legislative role in defining public policy)