Refusing to Define: Minnesota Supreme Court Clarifies Jury Instructions in DWI Test Refusal Cases
The Minnesota Supreme Court recently addressed a narrow but meaningful question about jury instructions in a case involving a refusal to undergo a court-ordered blood or urine test. The Court ultimately affirmed that the Court is not required to define the word “refuse” as an “act of unwillingness” when instructing juries on the elements of a DWI test refusal in Minnesota.
State v. Schmeichel
In Minnesota, it is a crime to refuse a court-authorized blood or urine test. During Schmeichel’s trial, the district court instructed the jurors that the State needed to prove beyond a reasonable doubt that she had “refused to submit to the test.” Schmeichel requested further instruction, asking the court to define DWI test refusal to the jury as an actual unwillingness to take the test, arguing that the plain meaning of refuse necessarily includes a mental state requirement. The district court denied this request, and the Minnesota Supreme Court was asked to decide whether this denial was an error.
The court applied a common two-step framework for analyzing jury instructions. First, it determined whether the Court abused its discretion, and second, it considered whether the error was harmless. Even erroneous instructions do not automatically justify a new trial. The Court concluded there was no abuse of discretion, as the statute used to charge Schmeichel clearly states that refusal is an element the State must prove beyond a reasonable doubt. Because the word “refuse” carries a commonly understood meaning, the court reasoned that further defining it to another commonly used phrase, such as “actual unwillingness,” was unnecessary and offered little clarity while potentially causing additional confusion. In this case, jurors can apply ordinary language to the factual circumstances without further clarification from the court.
Further, the court emphasized that whether Schmeichel refused the test was a fact question, and by declining to provide a further definition, the court preserved the jurors’ ability to apply a real-world understanding of the word “refuse.” This decision aligns with a common judicial trend of avoiding unnecessary semantics that often confuse those who are not well-versed in the law.
What Does This Mean for Us?
From a practical standpoint, State v. Schmeichel shows how difficult it can be for a court to overturn a conviction based on jury instructions. Typically, as long as the judge explains the law in a way the jurors can understand and it is statutorily accurate, the court is unlikely to step in. For our attorneys, this means that we must focus on the facts of the refusal rather than on wording distinctions.
What Does This Mean for You?
When you encounter a DWI test and do not take it, the court believes that the word refuse alone is clear enough for jurors to understand, so your alleged DWI test refusal will be based on a juror’s interpretation and common sense of what refusing is.
The jury will not need to understand in detail what a DWI test refusal is; they will simply be instructed to use common sense, and if it looks like you refused, then, based on State v. Schmeichel, you refused. This is why it is imperative that you understand DWI test refusal. When you get your time to call your attorney before testing, call North Star Criminal Defense. This way, our attorneys can instruct you on the best route to take when encountering a DMT or blood/urine test, and can guide you through the process, so down the line, you are not left alone to the interpretation of 12 arbitrary people.
Contact North Star Criminal Defense Today
With over 50 years of combined experience, our dedicated team knows how to leverage jury instructions to your advantage. Additionally, we have guided 100s of clients through the DWI test phase of a DWI investigation and will be there with you every step of the way. If you or someone you love is finding themselves asked to blow into a machine, call North Star Criminal Defense today.
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