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Mens rea is the state of mind that the prosecution, to secure a conviction, must prove that a defendant had when committing a crime; criminal intent or recklessness. Mens rea is an essential element of every crime at common law.
In the course of a standard contraband check conducted on school students' coats, a teacher found a folding knife in appellant's coat pocket. Appellant was convicted for possessing a dangerous weapon on school property under Minn. Stat. § 609.66, subd. 1d (1998), a felony offense. The court of appeals affirmed. Appellant challenged the conviction.
Under the circumstances, could the appellant’s conviction under Minn. Stat. § 609.66, subd. 1d (1998) be upheld?
On appeal, the court reversed, concluding that in light of the state's jurisprudential history requiring clear legislative intent to dispense with proof of mens rea and the courts' heightened concern when such proof related to felony level crimes, and because the weapon involved was not so inherently dangerous that appellant should be on notice that mere possession would be a crime, respondent state was required to prove that appellant knew he possessed the knife on school property as an element of the offense charged. The court remanded to the trial court to determine whether appellant had such knowledge.