## Facts

- Near 11:00 p.m. on December 17, 2001, a Rochester police officer saw Steven Allen Benniefield walking within about 61 feet of a school property line.
- The officer confirmed an outstanding arrest warrant, stopped Benniefield, and arrested him.
- During a pat-down search incident to arrest, the officer found a makeshift crack pipe in Benniefield’s pocket.
- Benniefield was transported to the detention center in a squad car.
- After the transport, officers searched the squad car and found a baggie containing off-white rocks later identified as 1.10 grams of cocaine.
- The state charged Benniefield with third-degree controlled-substance crime for possessing a Schedule II narcotic “in a school zone” under Minn. Stat. § 152.023, subd. 2(4).
- The statutory definition of “school zone” included the area surrounding school property to a distance of 300 feet or one city block, whichever was greater.

## Issues

1. Whether enhancing punishment for drug possession based solely on location within a “school zone” violates the equal protection guarantee of the Minnesota Constitution.
2. Whether Minn. Stat. § 152.023, subd. 2(4) requires proof that the defendant knew he was in a school zone or intended to possess drugs in a school zone.

## Decision

- The Minnesota Supreme Court affirmed the conviction for third-degree possession of a controlled substance in a school zone.
- The court held the school-zone enhancement survives rational-basis review under the Minnesota Constitution’s equal protection guarantee.
- The court held the statute’s location element (“in a school zone”) does not require proof of knowledge or intent regarding the defendant’s presence within the zone.

## Legal Principles

- When a statutory classification implicates neither a suspect class nor a fundamental right, Minnesota courts apply rational-basis review to equal protection challenges.
- A legislature may enhance penalties for drug offenses committed within defined sensitive locations, such as school zones, if the geographic classification is rationally related to a legitimate governmental interest, including protecting children and school environments from drug-related risks.
- If statutory language is plain and contains no mental-state term tied to a particular element, courts apply the text as written and do not add a mens rea requirement absent legislative direction.
- A location-based element may be treated as strict liability, so long as the underlying prohibited conduct remains culpable and is subject to the required mental state for the base offense.

## Conclusion

The Minnesota Supreme Court upheld the school-zone enhancement for controlled-substance possession, concluding it is rationally related to protecting children and that the statute does not require proof that a defendant knew of, or intended to be within, the school-zone boundaries.


State v. Benniefield, 678 N.W.2d 42 (Minn. 2004)