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State v. Benniefield

Minnesota Supreme Court
678 N.W.2d 42 (2004)


Facts

A police officer witnessed Steven Benniefield (defendant) walking close to the Riverside School property line late at night. After confirming that there was an outstanding warrant for Benniefield’s arrest, the officer arrested Benniefield. The officer discovered a crack pipe on Benniefield during a pat-down. After another officer drove Benniefield to the correctional center, the officer found a bag containing 1.1 grams of cocaine in the officer’s squad car. Bennifield was convicted of third-degree possession of a controlled substance within a school zone. At trial, Benniefield argued that he did not intend to be in a school zone and was merely walking the most direct route between work and his home. Benniefield appealed his conviction on the grounds that: (1) harsher punishments for drug possession inside school zones violate the equal protection guarantee of the Minnesota Constitution, and (2) the trial court erred by failing to instruct the jury that intent to be in a school zone was a required element of the offense. The court of appeals affirmed Benniefield’s conviction, and Benniefield appealed again on the same grounds.

Rule of Law

Issue

Holding and Reasoning (Hanson, J.)

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