State v. Mosbrucker

2008 ND 219, 758 N.W.2d 663, 2008 N.D. LEXIS 210, 2008 WL 5220856
CourtNorth Dakota Supreme Court
DecidedDecember 16, 2008
Docket20070355
StatusPublished
Cited by8 cases

This text of 2008 ND 219 (State v. Mosbrucker) is published on Counsel Stack Legal Research, covering North Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Mosbrucker, 2008 ND 219, 758 N.W.2d 663, 2008 N.D. LEXIS 210, 2008 WL 5220856 (N.D. 2008).

Opinions

VANDE WALLE, Chief Justice.

[¶ 1] Jeff Mosbrucker appealed from a criminal judgment entered after being found guilty of gross sexual imposition following a jury trial. We affirm.

I.

[¶ 2] In August 2006, Mosbrucker and Jane Doe, who was eighteen years old at the time, had sex outside her parent’s home. Mosbrucker was charged with gross sexual imposition for engaging in a sexual act with Doe, whom the State alleged was forced into the sexual act or had a mental disease or defect rendering her incapable of understanding the nature of the conduct. Mosbrucker’s first trial in March 2007 ended in a mistrial and a second trial was held in July 2007.

[¶ 3] At the close of the State’s case-in-chief, Mosbrucker moved for a judgment of acquittal. It was partially granted as to the allegation that Doe was forced into the sexual act, with the jury deciding only whether Mosbrucker knew or had reasonable cause to believe Doe suffered from a mental disease or defect rendering her incapable of understanding the nature of the conduct. The jury found Mosbrucker guilty of gross sexual imposition. Following his trial, Mosbrucker made a motion for a new trial on the grounds that the verdict was not supported by the greater weight of the evidence. The motion was subsequently denied by the trial court.

II.

[¶ 4] Mosbrucker argues his conviction should be reversed because the trial court committed obvious error by allowing Dr. DeGree to testify regarding Doe’s ability to consent to sexual acts and her ability to understand the implications of engaging in sexual acts.

[¶ 5] Dr. DeGree testified he reported the incident because Doe told him she had not intended to have sexual relations and because he thought she would have difficulty giving consent due to her lack of mental capability. When asked if Doe had a mental disease or defect rendering her incapable of understanding the nature of [666]*666the conduct, Dr. DeGree explained that Doe might understand the act of sexual intercourse but would have difficulty understanding the implications of it. He said Doe would have extreme difficulty understanding sexually transmitted diseases, becoming pregnant and “the social relationships you have to understand and negotiate in order to engage in [sex].” When asked whether Doe could consent to the act of sex, Dr. DeGree stated:

[T]he trouble I have with that is she would not understand the implications of it, having sexually transmitted diseases, being pregnant, having consenting sex with somebody who may not be a good partner. She would have serious limitations on that.

[¶ 6] Mosbrucker objected to the testimony at trial as irrelevant. The trial court overruled the objection. Relevant evidence is evidence having any tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence. N.D.R.Ev. 401. Under N.D.R.Ev. 401 through 403, a trial court is vested with broad discretion to decide if evidence is relevant and if its probative value is substantially outweighed by the danger of unfair prejudice. State v. Carlson, 1997 ND 7, ¶ 8, 559 N.W.2d 802. We apply an abuse of discretion standard of review to a district court’s evidentiary rulings and will not reverse the court’s ruling unless it is arbitrary, capricious, or unreasonable, or a misinterpretation or misapplication of the law. State v. Wegley, 2008 ND 4, ¶ 12, 744 N.W.2d 284.

[¶ 7] Mosbrucker argues the testimony regarding whether Doe could consent to the sexual act or understand the implications of having sex were irrelevant in determining whether she had a mental disease or defect rendering her incapable of understanding the nature of the conduct. He asserts the testimony regarding Doe’s understanding of the physical act of sexual intercourse was sufficient to establish she was capable of understanding the nature of the conduct.

[¶ 8] Section 12.1 — 20—03(l)(e), N.D.C.C., provides:

1. A person who engages in a sexual act with another, or who causes another to engage in a sexual act, is guilty of an offense if:
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e. That person knows or has reasonable cause to believe that the other person suffers from a mental disease or defect which renders him or her incapable of understanding the nature of his or her conduct.

[¶ 9] It is necessary for us to ascertain what “incapable of understanding the nature of his or her conduct” entails and, consequently, what evidence is relevant to the issue. Legislative history is silent and there is no case law in our jurisdiction discussing the meaning of this particular statutory language. However, case law in other jurisdictions with similar statutory language is helpful in ascertaining what evidence is relevant in determining whether a victim was capable of understanding the nature of a sexual act.

[¶ 10] In determining the meaning of the words “incapable of understanding the nature of his or her conduct,” decisions in other jurisdictions have recognized the tensions between the individual’s right to sexual freedom and the society’s interest in protecting the individual with a mental disease or defect. Elizabeth Reed, Criminal Law and the Capacity of Mentally Retarded Persons to Consent to Sexual Activity, 83 Va. L.Rev. 799, 806 (1997). Although most jurisdictions agree that consent means knowing, intelligent and [667]*667voluntary agreement to engage in sexual activity, courts disagree as to the degree to which these factors must be determined and have resulted in three definitions courts have used to define mental incapacity so as to render the person incapable of understanding the nature of his or her conduct. Id. at 813.

[¶ 11] The majority position interprets the standard of incapable of understanding the nature of his or her conduct to mean that the person does not know either the physiological aspects of sex or the possible consequences of sexual activity, such as pregnancy and the contraction of sexually transmitted diseases. A few jurisdictions have interpreted the term to have a broader meaning and, in addition to understanding of the sexual act involved and its consequences, also require that the person must appreciate the moral dimensions of the decision to engage in sexual conduct although the person is free to act contrary to those societal ideas. Finally, one jurisdiction, New Jersey, has established the most limited interpretation and, while requiring the person understand the nature and the voluntariness of the action does not require the person understand the risk and consequences of sexual conduct. Id. at 813-14.

[¶ 12] An example of the broad definition is People v. Easley, 42 N.Y.2d 50, 396 N.Y.S.2d 635, 364 N.E.2d 1328, 1332 (1977). A valid inquiry in determining whether one is so mentally defective as to trigger protection under the law is whether there is an awareness of the social or other cost of one’s conduct. Id. at 1333. To appreciate the nature and consequences of engaging in an act of sexual penetration, the victim must have the capacity to understand the full range of ordinary and foreseeable social, medical and practical consequences that the act entails. See also State v. Soura, 118 Idaho 232, 796 P.2d 109 (1990);

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Cite This Page — Counsel Stack

Bluebook (online)
2008 ND 219, 758 N.W.2d 663, 2008 N.D. LEXIS 210, 2008 WL 5220856, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-mosbrucker-nd-2008.