State v. Kremer
114 N.W.2d 88, 262 Minn. 190, 1962 Minn. LEXIS 697 (1962)
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Rule of Law:
A conviction for a strict liability offense cannot be sustained when the prohibited act was committed involuntarily due to circumstances beyond the defendant's control, such as a sudden and unforeseeable mechanical failure, and without any negligence on the part of the defendant.
Facts:
- A driver, the defendant, approached an intersection with a 'red flashing' traffic semaphore signal.
- The brakes on the defendant's vehicle suddenly and unexpectedly failed to operate.
- The defendant had experienced no prior trouble with the brakes before this incident.
- The defendant had no knowledge that the brakes were in a defective condition.
- Due to the brake failure, the defendant was unable to stop and proceeded through the intersection without stopping at the red signal.
Procedural Posture:
- Defendant was charged in Minneapolis municipal court with violating a city ordinance for failing to stop at a red flashing signal.
- At trial, the municipal court found as fact that the defendant was unable to stop due to sudden, unknown brake failure but still found the defendant guilty.
- Defendant appealed the judgment of conviction from the municipal court to the current appellate court.
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Issue:
Does a driver violate a strict liability traffic ordinance by failing to stop at a red flashing signal if the failure to stop was caused by a sudden, unexpected, and previously unknown mechanical failure of the vehicle's brakes, without any negligence on the driver's part?
Opinions:
Majority - Frank T. Gallagher, Justice
No. A driver does not violate a strict liability traffic ordinance under these circumstances. While the legislature can make an act criminal without regard to the defendant's intent to commit a crime, it is essential that the defendant intend to do the physical act that constitutes the crime. The rationale for strict liability—that a person is in a position to prevent the prohibited act with reasonable care—does not apply when there is no negligence and no intent to perform the act itself. Here, the trial court found the defendant was 'unable to stop' due to the unforeseeable brake failure, meaning he did not intend to proceed through the signal. Since the act was not voluntary and the defendant was not negligent, the conviction cannot be upheld.
Analysis:
This case establishes a crucial limitation on the doctrine of strict liability in criminal law. It clarifies that while strict liability offenses eliminate the need for the prosecution to prove 'mens rea' (a guilty mind), they do not eliminate the fundamental requirement of a voluntary 'actus reus' (a guilty act). The decision distinguishes between a defendant who is negligent or intentionally commits the prohibited act and one who does so involuntarily due to circumstances entirely beyond their control. This precedent provides a defense against strict liability charges where the defendant's conduct was truly accidental and blameless, reinforcing the principle that criminal law punishes voluntary acts.
