Jackson v. State
Alaska Court of Appeals
85 P.3d 1042 (2004)
Jackson (defendant), charged with driving on a suspended license, was given two future court dates but missed both. He was then charged with two counts of failure to appear, claiming he misremembered the first date and believed he needn't attend the second once he'd missed the first. His attorney asked for an instruction requiring the mental state and the physical failure to appear to coexist simultaneously; the judge instead instructed that conviction was proper if the failure to appear was the joint operation of a knowing mental state and the act. Jackson was convicted and appealed.
Whether criminal liability may be established through a causal relationship between the mens rea and actus reus of a crime, even where the two elements do not occur simultaneously.