State of Minnesota v. Alie Christine Theodore Dorn
887 N.W.2d 826, 2016 Minn. LEXIS 784 (2016)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The 'assault-harm' provision of Minnesota's assault statute is a general intent crime, requiring only that the defendant intended to commit the physical act that constitutes a battery, not that the defendant intended to cause the specific bodily harm that resulted from the act.
Facts:
- Alie Dorn and D.E. were attending a large outdoor party and were standing near a bonfire.
- Within Dorn's earshot, D.E. told a friend that Dorn looked like a drug dealer.
- After D.E. repeated the comment at Dorn's request, Dorn pushed D.E. in the chest with two hands, causing him to lose his balance and stumble backward.
- Dorn then pushed D.E. in the chest with two hands a second time.
- As a result of the pushes, D.E. fell into the burning embers of the bonfire.
- D.E. sustained significant burn injuries, which constituted 'great bodily harm'.
- Dorn admitted to intentionally pushing D.E. but stated she did not intend for him to fall into the fire.
Procedural Posture:
- The State charged Alie Dorn with first-degree assault in Minnesota district court, the court of first instance.
- After a bench trial, the district court convicted Dorn of the charge.
- Dorn, as appellant, appealed the conviction to the Minnesota Court of Appeals, an intermediate appellate court.
- The Court of Appeals affirmed the trial court's conviction.
- The Supreme Court of Minnesota, the state's highest court, granted a petition for review filed by Dorn, as appellant.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the 'assault-harm' provision of Minnesota's assault statute require proof that the defendant specifically intended to cause the resulting bodily harm, or is it sufficient to prove the defendant intentionally committed a physical act that constitutes a battery and resulted in the harm?
Opinions:
Majority - McKeig, J.
No. The assault-harm statute does not require proof that the defendant intended to cause the resulting bodily harm; it is a general intent crime satisfied by proof that the defendant intentionally committed the physical act which constitutes a battery. The State need only prove that the defendant intended to do the prohibited physical act, not that they intended to cause a particular result. The forbidden physical act in an assault-harm case is a battery, which is the intentional application of nonconsensual force against another person. Here, Dorn admitted she intentionally pushed D.E., which constitutes a battery. This intentional act satisfied the mens rea (intent) element of the crime. Even assuming the statute's use of the word 'inflict' requires direct causation, Dorn's actions were the direct cause of D.E.'s injuries because her push initiated the uninterrupted sequence of events that led to him falling into the fire moments later.
Analysis:
This decision reaffirms and clarifies that 'assault-harm' under Minnesota law is a general intent crime, meaning the prosecution's focus is on the defendant's intent to commit the physical act, not their intent regarding the consequences. This lowers the evidentiary burden for the state in cases where an act of battery leads to unexpectedly severe or unforeseeable injuries. By distinguishing the intent to commit the act that constitutes a battery from the intent to commit the crime of battery, the court reinforces the principle that mistake of law is not a defense to general intent crimes. The ruling solidifies that once an individual intentionally commits a battery, they are legally responsible for the resulting harm, regardless of whether that harm was intended.
