State v. Benniefield

A police officer saw Steven Benniefield (defendant) walking near Riverside School property late at night and, after confirming an outstanding warrant, arrested him; a pat-down turned up a crack pipe, and officers later found a bag containing 1.1 grams of cocaine in the squad car that had transported him. Benniefield was convicted of third-degree possession of a controlled substance within a school zone. At trial he argued he had no intent to be in a school zone and was simply walking the most direct route home from work. Benniefield appealed, arguing (1) the school-zone enhancement violates Minnesota's equal protection guarantee, and (2) the trial court should have instructed the jury that intent to be in a school zone was a required element. The court of appeals affirmed, and Benniefield appealed again on the same grounds.