State v. Wilson, 830 N.W.2d 849

Wilson was convicted of fleeing a peace officer by means other than a motor vehicle under Minn. Stat. § 609.487, subd. 6, after running from an officer responding to a stabbing at Sunny’s Bar in Minneapolis.
The district court held the offense is general-intent; Wilson sought a voluntary intoxication jury instruction arguing the offense has a specific-intent element.
The court of appeals affirmed the conviction determining the offense is general-intent; this Court granted review.
Officer Imming observed Wilson and Lawrence flee; Wilson later picked up a knife dropped by Lawrence during the chase, and the knife was recovered later.
Wilson’s offer of proof included testimony that she was intoxicated and would testify to alcohol’s impact on perception, supporting a voluntary intoxication theory.
The Court held the offense contains a specific-intent requirement, but the omission of a voluntary intoxication instruction was harmless beyond a reasonable doubt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether fleeing by other means is a specific-intent crime	Wilson argued the statute requires specific intent	State argued it is a general-intent crime	Fleeing by other means is a specific-intent crime
Whether Wilson was entitled to a voluntary intoxication jury instruction	Wilson met burden of production and offered intoxication explanation	District court did not instruct; insufficient for entitlement	Wilson entitled to voluntary intoxication instruction; district court erred
Whether the error was harmless beyond a reasonable doubt	Omission affected verdict; reversible error	Evidence overwhelmingly supports intent; error harmless	Omission deemed harmless beyond a reasonable doubt; conviction affirmed

State v. Fleck, 810 N.W.2d 303 (Minn. 2012) (analyze intent in similar dual-elude contexts; distinguishes general vs. specific intent)
State v. Torres, 632 N.W.2d 609 (Minn. 2001) (voluntary intoxication instruction standard; burden of production)
State v. Wahlberg, 296 N.W.2d 408 (Minn. 1980) (burden of persuasion for intoxication defense; due process considerations)
City of Minneapolis v. Altimus, 306 Minn. 462, 238 N.W.2d 851 (Minn. 1976) (burden of proof for intoxication defense; fair preponderance standard)
State v. Lee, 683 N.W.2d 309 (Minn. 2004) (harmless-error standard in evaluating jury instructions)
State v. Shoop, 441 N.W.2d 475 (Minn. 1989) (harmless error review guidance for jury instructions)
State v. Koppi, 798 N.W.2d 358 (Minn. 2011) (confirming harmless error review framework for voluntary intoxication claims)
State v. Leathers, 799 N.W.2d 606 (Minn. 2011) (statutory interpretation; general vs. specific intent considerations)
In re W.J.R., 264 N.W.2d 391 (Minn. 1978) (offer of proof context in evaluating evidence impact)