State v. Striggles
210 N.W. 782, 202 Iowa 1318 (1926)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Reliance on the decision of an inferior court or assurances from local officials does not constitute a valid defense in a criminal prosecution, particularly for statutory misdemeanors where specific intent is not an explicit element of the crime.
Facts:
- In the early part of 1923, gum- or mint-vending machines were installed in several businesses in Des Moines, Iowa.
- The Iowa Supreme Court had previously determined, in State v. Ellis, that such machines were gambling devices and prohibited by statute.
- On August 1, 1923, the municipal court of Des Moines rendered a decision holding that the machine in question was not a gambling device.
- Distributors of the machine secured a certified copy of the municipal court's decree and letters from the county attorney’s office and the mayor, all stating that the machine was not a gambling device.
- The distributors then presented these documents to Striggles, who conducted a restaurant in Des Moines, and induced him to allow them to install a machine in his place of business.
- Striggles relied on the contents of these papers when he gave permission for the installation of the machine, believing it to be legal.
Procedural Posture:
- In early 1925, the Polk County grand jury returned an indictment against Striggles, charging him with willfully and unlawfully keeping a house resorted to for gambling and permitting persons to play a gambling device.
- Striggles entered a plea of not guilty.
- Striggles was put on trial in a district court.
- During the trial, Striggles offered a certified copy of a municipal court judgment and letters from the county attorney and mayor as evidence, but the district court sustained objections to their admission.
- Striggles testified that he relied on these documents, and his counsel attempted to ask him questions about his reliance and belief that the machine was not a gambling device, but the district court sustained objections to this line of testimony.
- The district court found Striggles guilty and assessed the minimum fine.
- Striggles, as the appellant, appealed his conviction to the Supreme Court of Iowa.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Is reliance on a lower court's decision or assurances from local officials a valid defense to a criminal charge for keeping a gambling device when the state's highest court has already declared such devices illegal and criminal intent is not an explicit element of the statute?
Opinions:
Majority - Albert, J.
No. Reliance on the decision of an inferior court or assurances from local officials is not a valid defense to a criminal charge for keeping a gambling device, nor is it admissible to negate intent in a misdemeanor where intent is not a statutory element. The court distinguished the present case from State v. O’Neil, where reliance on a decision of the highest court (the Iowa Supreme Court) that was subsequently overturned was deemed a valid defense. The court explicitly stated that citizens are entitled to rely on decisions of the "court of highest jurisdiction," but not decisions of any court "inferior to the Supreme Court." Furthermore, in prohibitive statutes covering misdemeanors where no provision is made as to intention (i.e., words like 'knowingly' are not used), intention is not considered an element of the crime, especially when the act is forbidden by statute as an exercise of the state's police power. Citing Kletzing v. Armstrong, the court emphasized that such statutes aim to prevent acts inimical to public welfare without particular reference to injurious consequences to individuals. Therefore, the district court correctly excluded the evidence of the municipal court judgment and the letters, as well as testimony regarding Striggles' reliance and belief, because they did not establish a legal defense or negate a necessary element of the crime.
Analysis:
This case significantly clarifies the limited scope of the 'mistake of law' defense in Iowa, establishing a critical distinction between reliance on the highest court's rulings versus those of inferior courts or local officials. It reinforces the principle that individuals are generally expected to know the law as authoritatively declared by the highest judicial body. The decision also solidifies the treatment of malum prohibitum crimes, particularly public welfare offenses, by reaffirming that specific intent is not a necessary element unless explicitly required by the statute. This ruling has broad implications for the enforcement of regulatory and public safety laws, making it more challenging for defendants to escape liability based on erroneous legal advice from non-supreme court sources, and places a strong burden on individuals to ascertain the definitive legal status of an activity.
