Summary of Garnett v. State (1993)

Defendant: Garnett; the defendant had consensual sex with a 13 year old girl. There was sufficient evidence that showed that the defendant honestly believed that the girl was 16. The girl became pregnant and the defendant was charged under a Maryland statue which made it a felony to have sexual intercourse with a girl under the age of 14 if the man is 4 years older than the girl. The defendant was convicted and sentenced to 5 years of probation.

Issue: Did the state need to prove that the defendant had knowledge of the actual age of the victim in order to convict him under the statue?

Holding: No

Legal Reasoning: The court ruled that the legislature intended the statue to be a strict liability statue, even though it does not state that explicitly in the wording of the statue. The court stated that the statue did not require mens rea on the part of the defendant. The court further ruled that the Maryland legislature had the complete discretion in making the defendant’s offense a strict liability crime. So the conviction was affirmed.