State v. Fridley

Brief Fact Summary.

Defendant, Gaylord Fridley, was arrested and charged with driving with a revoked license, a strict liability offense.

Synopsis of Rule of Law.

A defendant may not assert a defense of mistake of law for strict liability offense because the prosecution is not required to prove criminal culpability.

Facts.

Fridley was pulled over for speeding and during a routine check, officers discovered that Fridley’s license had been revoked, which was a strict liability offense. At trial, Fridley sought to introduce evidence, which the prosecution objected to, that depicted a telephone conversation he had with an employee of the drivers license division. Fridley testified that the employee told him that he would have to take a drivers test, forward the appropriate documentation and payment to the division, if Fridley was to obtain a work permit to drive. Fridley was told that he would be without a license for seven days, which Fridley interpreted to mean that he was permitted to drive during this period. Fridley sought to introduce this evidence in support of his defense of mistake of law but the trial court sustained the prosecution’s objection to admittance of the evidence, because it was hearsay and denied his request the jury be instructed on a mistake of law defense. Fridley appealed.

Issue.

Whether a defendant may assert a defense of mistake of law for a strict liability offense because the prosecution is not required to prove criminal culpability.

Held.

No. A defendant may not assert a defense of mistake of law for strict liability offense because the prosecution is not required to prove criminal culpability.

Concurrence.

None

Discussion.

While a defendant may assert a defense of mistake of law if there is proof they had a good-faith belief their actions did not qualify as a crime, it cannot be asserted when the crime committed was a strict liability offense. The statute Fridley violated, which made it a misdemeanor to drive with a revoked license, is a strict liability offense under the statute, and the prosecution need not prove mental culpability. Thus, the trial court did not error in rejecting Fridley's request for a jury instruction on mistake of law.