State v. Stiffler
763 P.2d 308, 114 Idaho 935 (1988)
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Rule of Law:
Statutory rape is a strict liability offense, and therefore, an honest and reasonable mistake of fact as to the victim's age is not a valid defense to the charge.
Facts:
- Jason Stiffler engaged in an act of sexual intercourse with a female.
- The female was under the age of eighteen.
- Stiffler believed the female was eighteen years of age or older.
- The victim's appearance and the circumstances surrounding the act tended to support Stiffler’s claimed mistake as to the victim's age.
Procedural Posture:
- Jason Stiffler was charged with statutory rape in an Idaho district court (trial court).
- At trial, Stiffler proposed a jury instruction that would allow the jury to consider a reasonable mistake of fact as to the victim's age as a defense.
- The district court refused to give the proposed jury instruction.
- Stiffler then entered a conditional plea of guilty, which preserved his right to appeal the district court's refusal of his proposed instruction.
- Stiffler appealed the district court's decision to the Idaho Court of Appeals (intermediate appellate court).
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Issue:
Does an honest and reasonable mistake of fact as to the victim's age constitute a valid defense to a charge of statutory rape under Idaho Code § 18-6101(1)?
Opinions:
Majority - Swanström, J.
No. A reasonable mistake of fact as to the victim’s age is not a defense to statutory rape. The offense of statutory rape under I.C. § 18-6101(1) is a strict liability crime, meaning criminal intent regarding the victim's age is not a necessary element. The only intent required by I.C. § 18-114 is the general intent to knowingly perform the act of sexual intercourse. Since criminal intent as to age is not an element, the mistake of fact defense under I.C. § 18-201(1), which serves to disprove criminal intent, is inapplicable. The public policy of protecting minors, who are deemed legally incapable of giving consent, outweighs the defendant's subjective belief. While a defendant's reasonable belief may be considered as a mitigating factor during sentencing, it cannot absolve guilt.
Dissenting - Burnett, J.
Yes. A reasonable mistake of fact should be a defense to statutory rape. Idaho Code § 18-114 plainly states that 'In every crime' there must be a union of act and intent, and I.C. § 18-201(1) allows for a mistake of fact defense that disproves criminal intent. These statutes make no exception for statutory rape. Characterizing a serious felony like rape as a 'strict liability' offense is conceptually unsound, as that doctrine is typically reserved for regulatory offenses, not intrinsically bad acts. The question of whether the defendant's mistake was both honest and reasonable is a factual determination that should be made by a jury, not precluded as a matter of law.
Analysis:
This decision solidifies statutory rape as a strict liability crime in Idaho, placing the entire burden on individuals to be absolutely certain of their partner's age before engaging in sexual intercourse. The court explicitly rejects the approach taken by jurisdictions that allow a reasonable mistake of fact defense, prioritizing the state's public policy of protecting minors over the defendant's mental state. However, by allowing the defendant's reasonable belief to be considered as a mitigating factor at sentencing, the court creates a compromise that can temper the harshness of the strict liability rule in cases where the defendant's mistake was genuinely reasonable.
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