State v. Rohan
2013 Minn. App. LEXIS 68
Minn. Ct. App.2013Background
- Rohan served beer to an underage person identified by ID; officers conducted undercover check at a Burnsville bar.
- Statute Minn.Stat. § 340A.503, subd. 2(1) prohibits serving alcohol to underage persons and is at issue.
- District court held the statute is not strictly liable and must prove intent; it ordered the state to prove intent.
- State appealed pretrial under Minn.R.Crim.P. 28.04(1); argument centered on whether the statute is strict liability.
- Court must decide if the offense is a strict-liability crime consistent with due process; Ndikum and Neisen guide interpretation.
- Majority reverses district court, holding the statute is a strict-liability crime and does not violate due process; remand for reinstatement of charges.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 340A.503(2)(1) include an intent element? | State contends statute is strict liability. | Rohan argues due process requires intent. | Statute is strict liability; no intent element required. |
| Does due process require reading an intent element into § 340A.503(2)(1)? | State claims no due-process violation for strict liability. | Rohan argues due process forbids strict liability without intent. | Due process does not require an intent element. |
Key Cases Cited
- State v. Ndikum, 815 N.W.2d 816 (Minn. 2012) (public-welfare offenses and mens rea framework; penalties influence necessity of mens rea)
- Staples v. United States, 511 U.S. 600 (U.S. 1994) (determining mental state requires statutory construction and inference of intent)
- United States v. Balint, 258 U.S. 250 (S. Ct. 1922) (definition of mens rea and knowledge of illegality)
- In re Welfare of C.R.M., 611 N.W.2d 802 (Minn. 2000) (public welfare concepts in Minnesota context)
- Neisen v. State, 415 N.W.2d 326 (Minn. 1987) (carding defense; legislative intent to dispense with mens rea)
- State v. Heck, 23 Minn. 549 (Minn. 1877) (historical view on strict liability for underage liquor sales)