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State v. Fridley | 335 N.W.2d 785 (1983)
In some cases, a defendant’s good-faith belief that his actions are legal is a valid defense to a crime. In State versus Fridley, the North Dakota Supreme Court considered whether that defense applied when a defendant was prosecuted for a crime that had no element of mental culpability.
After police officers stopped Gaylord Duane Fridley for speeding, a routine driver’s license check revealed that Fridley’s license had been revoked. The officers arrested Fridley for driving with a revoked license, which was a strict liability offense under North Dakota law.
Before trial, the prosecution filed a motion in limine requesting that the court exclude evidence of Fridley’s phone conversation with Debbie, a state driver’s license division employee. Fridley argued that he planned to introduce evidence of that conversation in support of a mistake-of-law defense. At a hearing, Fridley testified that he called the driver’s license division after receiving notice that his license had been revoked. Debbie informed him that obtaining a work permit to drive required a driver’s test and sending paperwork and payment to the division. Debbie also told Fridley that while his application was processed, he wouldn’t have a license for seven days. Fridley testified that he interpreted Debbie’s statement to mean that he would be permitted to drive during the processing period. The trial court granted the prosecution’s motion, holding that evidence of Debbie’s statements would be inadmissible hearsay and didn’t qualify as an official interpretation of state law.
At trial, the court denied Fridley’s request that the jury receive an instruction on the defense of mistake of law. The jury found Fridley guilty, and Fridley appealed to the North Dakota Supreme Court.
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