State v. Wilson
2012 Minn. App. LEXIS 40
Minn. Ct. App.2012Background
- Appellant Wilson was charged with violating Minn.Stat. § 609.487, subd. 6 (attempting to evade a peace officer by non-motor-vehicle means, a misdemeanor).
- Before trial, Wilson sought a voluntary-intoxication jury instruction arguing the offense has a specific intent.
- The district court denied the instruction, reasoning the offense is not a specific-intent crime.
- During the incident, Wilson ran with a knife after a police officer attempted to talk to her and the suspect about a bar stabbing; the officer pursued, tackled, and injured his ankle.
- The knife was found in a window well near where Wilson was grabbed; Wilson was convicted of the charged offense.
- The question on appeal is whether § 609.487, subd. 6 requires a specific intent to evade a peace officer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 609.487, subd. 6 require specific intent? | Wilson argues the statute is a specific-intent crime. | State argues the statute lacks the specific-intent language; no instruction required. | No; § 609.487, subd. 6 lacks explicit specific-intent language, so voluntary intoxication not available. |
Key Cases Cited
- State v. Fleck, 810 N.W.2d 303 (Minn. 2012) (distinguishes specific vs. general intent; guides interpreting 'with intent' language)
- State v. Torres, 632 N.W.2d 609 (Minn. 2001) (voluntary intoxication applies to specific-intent crimes when element exists and defense is raised)
- State v. Johnson, 374 N.W.2d 285 (Minn.App. 1985) (addresses implied specific-intent in fleeing a peace officer by motor vehicle)
- City of Minneapolis v. Altimus, 306 Minn. 462, 238 N.W.2d 851 (1976) (voluntary intoxication defense linked to specific intent; language discussed in Fleck)