State v. Brown
2011 WL 2302319, 2011 Minn. App. LEXIS 70, 801 N.W.2d 186 (2011)
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Rule of Law:
Under Minnesota law, a motorized mobility scooter used by a disabled person as a substitute for walking is considered a 'wheelchair,' and its operator a 'pedestrian.' Such a device is not a 'motor vehicle' for the purposes of the Driving While Impaired (DWI) statute.
Facts:
- James Anthony Brown, Jr. is a physically disabled individual.
- Brown uses a battery-operated, three-wheel mobility scooter as a substitute for walking.
- The scooter has a maximum speed of 5.75 miles per hour.
- On July 29, 2009, Brown operated his scooter on the sidewalks of Grand Rapids, including in an automobile display lot at a car dealership.
- Employees at the car dealership contacted police regarding a possibly intoxicated individual.
- Police arrived, arrested Brown for DWI, and administered a breath test.
- The breath test revealed Brown had an alcohol concentration of .17.
- Brown had a prior DWI conviction from 2001.
Procedural Posture:
- The State charged James Anthony Brown, Jr. with third-degree Driving While Impaired (DWI) in district court.
- Brown's pretrial challenges to the charges were rejected by the district court.
- The case was submitted to the district court for trial based on a set of stipulated facts.
- The district court found Brown guilty of third-degree DWI and imposed a sentence.
- Brown (appellant) appealed his conviction to the Minnesota Court of Appeals.
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Issue:
Does a motorized mobility scooter, used by a physically disabled person as a substitute for walking, qualify as a 'motor vehicle' under Minnesota's DWI statute, Minn.Stat. § 169A.20, subd. 1?
Opinions:
Majority - Stoneburner, Judge.
No. The operation of a motorized mobility scooter as a substitute for walking does not constitute driving a 'motor vehicle' within the meaning of Minnesota's DWI statute. The court reached this conclusion by reading the DWI statute (Chapter 169A) in conjunction with the general traffic regulations (Chapter 169). Chapter 169 defines 'wheelchair' to include motorized scooters used by disabled persons and defines 'pedestrian' to include a person in a wheelchair. Although the DWI statute has a broad definition of 'motor vehicle,' it incorporates the definition of 'vehicle' from Chapter 169, which is a device for transport 'upon a highway.' Because scooters are generally restricted to sidewalks and not highways, they do not qualify as 'vehicles,' and therefore cannot be 'motor vehicles' under the DWI law. To hold otherwise would lead to an absurd result not intended by the legislature.
Analysis:
This decision clarifies the legal status of personal mobility devices under Minnesota's DWI laws, preventing an expansive and potentially absurd application of the statute. It serves as a key example of statutory interpretation, demonstrating the principle of reading different statutes 'in pari materia' (on the same subject) to create a harmonious and sensible legal framework. The court's focus on avoiding an 'absurd result' signals to lower courts that legislative intent and common sense should guide the application of statutes, particularly when a literal reading might lead to unintended consequences. This precedent effectively insulates users of disability-assistance devices from DWI prosecution for the operation of those specific devices.
