Can a defendant be convicted of statutory rape in Maryland without proof that they knew the victim was underage, and should evidence of the defendant's belief about the victim's age be allowed in court?

Raymond Lennard Garnett, a 20-year-old man with an IQ of 52, engaged in sexual intercourse with Erica Frazier, a 13-year-old girl. Garnett entered Erica's bedroom through a window at her invitation. He claims that Erica and her friends told him she was 16 years old. As a result of their sexual encounter, Erica later gave birth to Garnett's child.

Garnett was subsequently charged with second degree rape under Maryland Code Art. 27, § 463(a)(3). This statute prohibits sexual intercourse between a person under 14 years of age and another individual who is at least four years older. The charge was brought despite Garnett's assertion that he believed Erica to be 16 years old at the time of the incident.

Garnett was initially tried in the Circuit Court for Montgomery County. During the trial, the court excluded evidence related to Garnett's belief about Erica's age, deeming it immaterial. The jury found Garnett guilty. Following his conviction, Garnett appealed the decision. The Court of Appeals of Maryland, bypassing the intermediate Court of Special Appeals, granted certiorari to review the case directly.

(Murphy, J.)

Yes. A defendant can be convicted of statutory rape in Maryland without proof of knowledge of the victim's age, and evidence of the defendant's belief about the victim's age is inadmissible. Maryland's statutory rape law defines a strict liability offense that does not require the State to prove mens rea regarding the victim's age. The plain language of the statute, its legislative history, and the traditional view of statutory rape as a strict liability crime support this interpretation. While many jurisdictions have moved away from strict liability for statutory rape, Maryland's legislature has not done so. The statute's purpose is to protect children from sexual exploitation, regardless of the defendant's mental state or mistaken beliefs. This approach places the risk of mistake squarely on the adult engaging in sexual activity with a young person. The legislature has made a policy decision to prioritize the protection of minors over the potential unfairness to defendants who may have been mistaken about a victim's age. This strict liability standard serves as a strong deterrent, encouraging adults to exercise extreme caution in sexual relationships with younger partners. Any change to introduce a mens rea element or allow a mistake-of-age defense must come from the legislature, not the judiciary. The courts are bound to interpret and apply the law as written, and the current statutory language clearly establishes statutory rape as a strict liability offense in Maryland.

Dissent (Eldridge, J.) While a defendant's mistake about the victim's age may not be a defense, the statute does not preclude consideration of the defendant's mental state entirely, especially in cases involving defendants with mental impairments. The majority's interpretation as a pure strict liability offense is overly broad and fails to account for nuanced situations where a defendant's mental capacity may be relevant.

Dissent (Bell, J.) Due process requires the State to prove the defendant's intent or knowledge in a statutory rape case, and the defendant should be allowed to present evidence of mistake of age as a defense. Strict liability for statutory rape violates due process, especially given the severe penalties and stigma associated with the crime. This interpretation better balances the need to protect minors with fundamental principles of criminal justice.