State v. Nations
676 S.W.2d 282 (1984)
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Rule of Law:
Under Missouri's criminal code, the mens rea of 'knowingly' requires proof of the defendant's actual knowledge of the attendant circumstances; evidence showing only an awareness of a high probability of a fact's existence proves 'recklessness,' not 'knowledge.'
Facts:
- Sandra Nations owned and operated the Main Street Disco.
- Police officers entered the disco and observed a sixteen-year-old girl dancing on stage for tips in a scantily clad manner.
- Nations had hired the girl on the same day the police arrived.
- The girl did not have any identification with her.
- When questioned by police, Nations stated she had checked the girl's identification and that she was of legal age.
- The girl initially told police she was eighteen but later admitted to being sixteen.
Procedural Posture:
- Sandra Nations was charged with endangering the welfare of a child in a Missouri trial court.
- Following a trial, Nations was convicted and fined $1,000.00.
- Nations, as the appellant, appealed her conviction to the Missouri Court of Appeals, arguing the state failed to prove its case.
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Issue:
Does evidence that a defendant was aware of a high probability that an attendant circumstance exists satisfy the statutory requirement that the defendant acted 'knowingly' with respect to that circumstance?
Opinions:
Majority - Satz, J.
No. Evidence that a defendant was aware of a high probability that an attendant circumstance exists does not satisfy the statutory requirement of acting 'knowingly,' but rather proves recklessness. The Missouri legislature adopted the Model Penal Code's definition for 'knowingly' but deliberately omitted the provision that would have expanded it to include 'willful blindness' or awareness of a high probability of a fact's existence. Therefore, the statute requires proof of actual, subjective knowledge. Here, the state's evidence—that Nations lied about checking the girl's ID—proves at most that Nations was aware of a high probability the girl was underage and consciously disregarded the risk. This meets the statutory definition of 'recklessness' but falls short of the required mental state of 'knowledge' for the crime charged.
Analysis:
This decision strictly interprets the statutory mens rea of 'knowingly,' distinguishing it from 'recklessness' and 'willful blindness.' By focusing on the legislature's deliberate omission of the Model Penal Code's expanded definition of knowledge, the court solidifies that actual, subjective awareness must be proven for crimes requiring a 'knowing' state of mind as to an attendant circumstance. This raises the burden of proof for the prosecution in such cases, as it cannot substitute evidence of a defendant's conscious avoidance of facts for proof of actual knowledge. The ruling emphasizes that courts must adhere to precise statutory definitions, even if it creates a potential loophole where defendants can escape liability by deliberately remaining ignorant.
