State of Minnesota v. Kevin John Motz, A15-1918

On Nov. 8, 2014, 17-year-old N.C. ran away with boyfriend B.T.; Kevin Motz (age >18, >24 months older than N.C.) picked her up and brought her to B.T.’s home.
Motz answered a police call on speaker, told N.C. he knew he would be in trouble for helping her, and instructed N.C., B.T., and B.T.’s mother to stay low and away from windows to avoid police detection.
Motz urged N.C. and B.T. to leave after dark, refused to drive them because he feared legal trouble, and asked N.C. to disable her phone so she could not be located; police found the youths about 20 miles away.
State charged Motz with deprivation of parental rights under Minn. Stat. § 609.26; Motz asserted the statutory affirmative defense that he reasonably believed his actions were necessary to protect N.C. from substantial emotional harm (claiming he thought N.C. was pregnant and feared parental coercion to abort or give up the child).
At trial, the jury credited N.C.’s testimony that she did not discuss a pregnancy with Motz and that Motz never offered to take her to a family-planning shelter; B.T. initially failed to mention a pregnancy to police and told the prosecutor N.C. did not tell Motz about a possible pregnancy.
The jury convicted Motz; on appeal he argued the state failed to disprove his affirmative defense beyond a reasonable doubt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence disproved Motz's affirmative defense that he reasonably believed his actions were necessary to protect the child from substantial emotional harm	State: N.C.'s testimony contradicted Motz and showed he did not reasonably believe protection from emotional harm was necessary	Motz: He testified N.C. told him she might be pregnant and he acted to prevent parental coercion (offer to take her to family-planning shelter)	The jury credited N.C.; her testimony, if believed, disproved Motz's defense. Sufficient evidence supports conviction

Merrill v. State, 274 N.W.2d 99 (Minn. 1978) (standard for reviewing sufficiency of the evidence)
Moore v. State, 438 N.W.2d 101 (Minn. 1989) (view evidence in light most favorable to verdict)
Pieschke v. State, 295 N.W.2d 580 (Minn. 1980) (defer to jury on conflicting testimony)
Niska v. State, 514 N.W.2d 260 (Minn. 1994) (state must disprove statutory affirmative defense beyond a reasonable doubt once defendant fairly puts it at issue)
Cao v. State, 788 N.W.2d 710 (Minn. 2010) (a conviction may rest on the uncorroborated testimony of a single credible witness)
Dickerson v. State, 481 N.W.2d 840 (Minn. 1992) (deference to jury credibility findings), aff'd, 508 U.S. 366 (1993) (Supreme Court affirmation of credibility-deference principle)