Garnett v. State

Garnett (defendant), a mentally handicapped 20-year-old with the social development of an 11- or 12-year-old, had sexual intercourse with 13-year-old Erica Frazier at her invitation. Maryland's second-degree rape statute criminalized intercourse between a victim under 14 and someone four or more years older, with no stated mens rea or mistake-of-fact defense for that provision, while a separate provision covering victims who are mentally handicapped, incapacitated, or physically helpless did require the defendant to know or should have known of that condition.