Fordyce v. State
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The Supreme Court affirmed Defendant's conviction, following a jury trial, of gross-misdemeanor indecent exposure, holding that an individually who willfully and lewdly exposes himself in the privately-owned, partially-enclosed backyard of his home has done so in a "in any place where others are present" within the meaning of the indecent-exposure statute, Minn. Stat. 617.23, subd. 1.
After he was convicted, Defendant filed a petition for postconviction relief, arguing that the State failed to prove that he was in a "public place, or in any place where others are present" within the meaning of the statute. The district court denied the petition, concluding that Defendant's actions occurred in a public place. The court of appeals affirmed. The Supreme Court affirmed, holding that the privately-owned, partially-enclosed backyard of a home satisfies the "place" element of the indecent-exposure statute.
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