Background
On November 19, 2022, police responded to a restaurant in Austin, Minnesota, where they found Terry Izeal Heggs, a restaurant employee, in the presence of a woman with whom he had been in an intimate relationship. Officers observed a furnished room with a mattress, television, and men’s clothing, and a subsequent warranted search revealed personal-care items and documents in Heggs’s name, suggesting he was staying overnight at the restaurant. Heggs was charged with four offenses, including failure to register as a predatory offender in violation of Minn. Stat. § 243.166, subd. 5(a)(1).
Approximately one month before his arrest, Heggs had updated his predatory offender registration by completing a change-of-information form on which he listed his restaurant workplace address under “Current Employment Information” but left blank the section for “Current Secondary and Other Addresses.” Three weeks later, he signed an address-verification form on which his workplace address appeared but the “New Secondary Address” field remained blank. A jury found Heggs guilty in April 2023. The district court granted his post-trial motion for judgment of acquittal. The state appealed to the Court of Appeals, which reversed and reinstated the conviction in July 2024, finding circumstantial evidence sufficient to prove Heggs was regularly staying overnight at the workplace address. Heggs then appealed this reinstatement.
The Court’s Holding
The Minnesota Court of Appeals reversed Heggs’s conviction, holding that the state did not prove beyond a reasonable doubt that Heggs knowingly violated the predatory-offender-registration statute. The court concluded that while the predatory-offender-registration statute requires registrants to provide both their secondary addresses and employment addresses, the statute does not expressly require that information be provided separately or in particular categories on registration forms. Critically, the statute does not require a registrant to specify the statutory categories that apply to the information provided. The court found that Heggs actually provided the restaurant address twice on his registration forms—once under employment information and once in pre-printed form—thereby providing the address information required by statute.
However, the court’s primary holding concerned the knowledge element of the offense. The statute requires that a person “knowingly” violate the registration requirements. The court determined that when knowledge of the law is an element of a criminal offense, it typically must be proved through circumstantial evidence and is subject to the heightened scrutiny applied to circumstantial-evidence convictions. Applying this standard, the court identified the circumstances proved: Heggs provided the address on both forms, left the secondary-address field blank, initialed paragraphs on the verification form, but was regularly staying overnight at the workplace. The court found that a reasonable inference supporting guilt (that Heggs knew he should be more specific) was contradicted by an equally rational hypothesis inconsistent with guilt: that Heggs believed he was in compliance by listing the address as his employment address and did not believe the statute required him to also designate it as a secondary address. Absent evidence that Heggs subjectively believed he was required to specify the dual nature of the address, the state failed to prove the knowing-violation element beyond a reasonable doubt.
Key Takeaways
- The predatory-offender-registration statute does not expressly require information to be presented in particular formats or categories or require duplication of an address across multiple form sections, even if the address satisfies multiple statutory categories.
- Knowledge of the law is an element of a predatory-offender-registration violation; a defendant’s mistake of law negates this element when the defendant’s interpretation of statutory requirements differs from the prosecution’s.
- Circumstantial evidence of knowledge is subject to heightened scrutiny: there must be no rational hypothesis other than guilt that is consistent with the circumstances proved.
Why It Matters
This decision significantly impacts predatory-offender registration enforcement by requiring prosecutors to prove not merely that a registrant failed to comply with the statutory form or structure, but that the registrant knew or should have known that his or her interpretation of the statute’s requirements was incorrect. The court’s analysis reinforces that technical compliance issues—particularly when the substantive information required by statute has been provided to authorities—cannot support a conviction absent evidence of knowledge of the legal violation. Where a registrant provides all required information, even if organized differently than the registration form’s structure suggests, a reasonable jury could conclude the registrant believed he was complying with the law. This places significant constraints on prosecution theories premised on improper form completion when the content of the required information has been disclosed.