State v. Jama
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The Supreme Court affirmed the decision of the court of appeals affirming the district court’s denial of Appellant’s request for a jury instruction on the defense of voluntary intoxication, holding that Minn. State. 617.23(2), the indecent-exposure statute, does not require the State to prove that the defendant had a specific intent to be lewd.
Defendant was charged with indecent exposure in the presence of a minor under the age of sixteen. After concluding that the indecent-exposure statute creates a general-intent crime, the district court denied Defendant’s request that the jury be instructed on the defense of voluntary intoxication because that defense only applies to specific-intent crimes. The jury found Defendant guilty. The court of appeals affirmed. The Supreme Court affirmed, holding that the offense of indecent exposure is a general-intent crime, and therefore, the court of appeals did not err when it affirmed the district court’s denial of Defendant’s request for a jury instruction on the defense of voluntary intoxication.
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