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Garnett v. State

632 A.2d 797 (Md. 1993)

tl;dr: A statute that defines statutory rape as a strict liablity crime does not require the state to prove mens rea.

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The case of Raymond Lennard Garnett v. State of Maryland was heard by the Court of Appeals of Maryland in September 1993. The court considered whether the state needed to prove that the defendant knew the victim was under 14 and whether it was an error to exclude evidence that the defendant believed the victim was 16. Raymond Garnett engaged in sexual intercourse with Erica Frazier, who was 13 years old at the time, and later gave birth to a child of which Raymond is the biological father. Raymond was tried for second-degree rape under ยง 463(a)(3), which prohibits sexual intercourse between a person under 14 and another at least four years older than the complainant. The defense attempted to introduce evidence that Erica had previously told Raymond she was 16 years old, but the trial court excluded it as immaterial since the only requirements for the charge were vaginal intercourse and Erica being under 14 while Raymond was at least four years older. Consent and good faith defense based on victim's age representation are not defenses in a statutory rape charge. The defendant was found guilty and sentenced to probation, restitution, and a suspended prison sentence. The case was appealed to the Court of Special Appeals for review. In 1976, Maryland law regarding rape and other sex crimes was revised, introducing a four-year age difference requirement between the accused and the underage complainant in the statutory rape law. Sexual intercourse with a person under 14 by an actor more than four years older was classified as rape in the first degree, carrying a maximum penalty of life imprisonment. The crime was later reduced to rape in the second degree with a maximum sentence of 20 years in prison.

The accused argues for a defense of reasonable mistake as to the complainant's age, but the trial court did not allow it. The legal issue is whether the accused should have been allowed to argue that he reasonably believed the victim was of legal age to consent to sexual relations. The lower court erred in treating a sexual offense as a strict liability offense without considering mens rea. The case should be reversed and remanded for a new trial. A mistake of fact can negate the required mental state for a crime, and in cases of self-defense, a defendant who subjectively believed their actions were necessary and objectively they were, is completely exonerated.

Mistake of age can be a defense to statutory rape, especially if there is no threat of force. Strict liability crimes like statutory rape violate due process because they create an irrebuttable presumption that the defendant's mental state is irrelevant. The Maryland statute for statutory rape violates due process because it removes the defense of reasonable ignorance of the victim's age and consequent lack of criminal intent. Proof of scienter is required for conviction to avoid violating the Constitution.

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Facts & Holding

Facts:The defendant was a 20 year old man who was...

Holding:The statute does not make reference to intent or knowledge,...

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Garnett v. State

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