State v. Yanez
Supreme Court of Rhode Island
716 A.2d 759 (1998)
Alejandro Yanez (defendant), 18, met a girl named Allison on the street and took her on a date; the two later had sex. Allison's mother learned of the encounter and called police. Yanez admitted the sex was consensual but said Allison had told him she was 16; she was actually 13. He was charged with first-degree child molestation sexual assault. At trial, the court refused to let Yanez introduce evidence of his reasonable but mistaken belief about her age, ruling mistake of fact was not a defense to the crime. He was convicted and sentenced to 20 years, with 18 suspended, and appealed.
Whether due process requires allowing a defendant to raise a reasonable mistake about the victim's age as a defense to the strict-liability crime of child molestation sexual assault.