State of Minnesota v. Juanel Anthony Mikulak, A15-1701

Background

Mikulak was a required predatory-offender registrant after a 2008 conviction and originally listed a St. Cloud (Stearns County) primary address.
After his girlfriend asked him to leave, Mikulak went to Danube (Renville County) and stayed with D.T. beginning October 17, 2014.
He visited the Renville County Sheriff’s Department but did not complete registration paperwork, believing he had a week to register.
The registration materials he had previously signed informed him that, if he lacked a primary address, he must register in the jurisdiction where he was staying within 24 hours.
He was charged with failing to register as a predatory offender in violation of Minn. Stat. § 243.166 and pleaded guilty; the district court accepted the plea and sentenced him to 36 months.
On appeal Mikulak argued the plea lacked an adequate factual basis and that he did not “knowingly” violate the statute because he did not know the 24-hour requirement.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was an adequate factual basis for the guilty plea that Mikulak lacked a primary address, stayed in Danube, and failed to register within 24 hours	The record (defendant’s own plea hearing testimony) shows he was told to leave, went to Danube for the weekend, visited the sheriff but did not register — supporting the elements	He testified he still had personal items at the Stearns County residence and did not explicitly admit being in one jurisdiction for 24 continuous hours, so the record is insufficient	The court held the testimony (arrival on Friday and staying “for the weekend”) supplies an adequate factual basis that he stayed more than 24 hours in Danube and failed to register
Whether the record proves he was in the same jurisdiction for 24 hours	State: testimony he arrived Friday and stayed "for the weekend" reasonably means >24 hours	He argued ‘‘weekend’’ is ambiguous and he didn’t confirm staying the whole time in Danube	Court adopted the common meaning of "weekend" and found the testimony sufficed to show presence >24 hours
Whether the state had to prove Mikulak knew the statute required registration within 24 hours (i.e., knowledge of the legal requirement)	State: under Minnesota law, "knowingly" requires belief in the factual elements (no primary address, stayed in Danube, failed to register), not knowledge of the statute’s timing; ignorance of law is no excuse	He argued he did not know the 24-hour requirement, so could not have knowingly violated the statute	Court held that proof of knowledge of the facts suffices; defendant’s mistaken belief about the registration deadline does not negate the element of acting "knowingly"

Key Cases Cited

State v. Lyle, 409 N.W.2d 549 (Minn. App. 1987) (trial court must ensure plea is accurate, voluntary, intelligent, and factually supported)
State v. Trott, 338 N.W.2d 248 (Minn. 1983) (same plea-advice and factual-basis principles)
State v. Watkins, 840 N.W.2d 21 (Minn. 2013) (knowledge of what a protective order prohibits relevant to mens rea questions)
State v. Gunderson, 812 N.W.2d 156 (Minn. App. 2012) (defendant’s understanding of the scope of an order affects culpability)
State v. King, 257 N.W.2d 693 (Minn. 1977) (ignorance of the law is no excuse; individuals are presumed to know laws affecting usual activities)
Bryan v. United States, 524 U.S. 184 (1998) ("knowingly" generally requires proof of knowledge of the facts that constitute the offense, not knowledge of the legal proscription)