Bell v. State
Court of Appeals of Alaska
668 P.2d 829 (Alaska Ct. App. 1983)
Relevant factsFree
Willie Bell (defendant) procured three teenage girls to work as prostitutes. Prosecutors charged him with first-degree promotion of prostitution because one girl was under 16. At trial, Bell asked for a jury instruction allowing a reasonable-mistake-of-age defense; the trial court refused, and the jury convicted him. Bell appealed, arguing that convicting him without requiring proof he knew the girl's age violated due process by dispensing with criminal intent.
IssueFree
Whether mistake of age is a defense to a crime that the legislature has classified as condemnable, or malum in se, regardless of the victim's actual age.