Wurthmann v. State

MANNHEIMER, Judge,

dissenting.

I agree with my colleagues that most of Wurthmann's convictions should be affirmed. However, I conclude that Wurthmann's two convictions for third-degree sexual abuse of a minor must be reversed. Although Wurth-mann engaged in sexual penetration with A.L., he did not occupy a "position of authority" in relation to her, and thus his conduct does not fall within the legislature's definition of the crime.

The legal problem presented here

Wurthmann engaged in sexual penetration with A.L. when she was between the ages of 16 and 18. Under Alaska law, the normal age of consent for sexual activity is 16. That is, AL. could validly consent to sexual activity with most adults. But the legislature has raised the age of consent in various situations *769in which the adult has a special relationship with the teenager.

One of these exceptions is for adults who occupy a “position of authority” with respect to the teenager. The terra “position of authority” is defined in AS 11.41.470(5). This statute declares that “position of authority” refers to adults who are the teenager’s

employer, youth leader, scout leader, coach, teacher, counselor, school administrator, religious leader, doctor, nurse, psychologist, guardian ad litem, babysitter, or [who occupy a] substantially similar position[.]

All of these adults, because of their professional or quasi-professional roles, are deemed to have greater influence over teenagers, thus justifying the legislature in enacting special provisions to govern their sexual relations with teenagers.

But Wurthmann did not occupy any of these professional or quasi-professional roles with respect to A.L. Rather, he was the live-in boyfriend of A.L.’s mother. True, Wurth-mann’s relationship with A.L.’s mother lasted for many years, and he came to occupy the role of A.L.’s de facto stepfather. But Wurthmann does not easily fit into any of the categories of adults mentioned in the statutory definition of “position of authority”. Instead, Wurthmann seems to be squarely covered by another special category of adults defined in the sexual abuse statutes: adults who “resid[e] in the same household as the [teenager] and ... ha[ve] authority over the [teenager]”.1

If Wurthmann had been charged with first- or second-degree sexual abuse of a minor, it would make no difference whether he was a “same household” adult or a “position of authority” adult. The statutes defining first-degree and second-degree sexual abuse of a minor treat these two groups of adults exactly the same. Both groups are treated more harshly than other adults if they engage in sexual penetration with a teenager who is 13, 14, or 15 years old. (They are guilty of first-degree sexual abuse rather than second-degree sexual abuse.)2 Likewise, both groups are treated more harshly than other adults if they engage in sexual contact with a teenager who is 13, 14, or 15 years old. (They are guilty of second-degree sexual abuse rather than third-degree sexual abuse.)3

But Wurthmann was charged with third-degree sexual abuse, and here the legislature did not treat the two groups the same. Under AS 11.41.438(a)(2), “position of authority” adults are guilty of third-degree sexual abuse if they engage in sexual penetration with a 16- or 17-year-old. However, this statute does not contain a parallel provision governing “same household” adults. Therefore, if the State was to convict Wurthmann of third-degree sexual abuse, it was not enough for the State to prove that he lived in the same household as A.L. and exercised authority over her. Rather, the State had to prove that Wurthmann held a “position of authority” over A.L. as that term is defined in AS 11.41.470(5).

Why I conclude that Wurthmann did not occupy a “position of authority” ivith respect to A.L.

The statutory provisions dealing with “same household” adults were enacted in 1988, while the “position of authority” provisions were not enacted until two years later, in 1990. Obviously, the legislature thought that they needed to create a new category, “position of authority”, to deal with situations that were not already covered by the “same household” provisions. But more important, for purposes of deciding Wurthmann’s case, is the fact that the legislature did not delete the “same household” provisions when they enacted the “position of authority” provisions. This means that the legislature did not think that the new category (adults in positions of authority) encompassed the old *770category (adults residing in the same household who exercise authority over the child).

This conclusion-that the legislature did not think these two groups were the same-is emphasized most vividly by the wording of AS 11.41.4388, the third-degree sexual abuse of a minor statute. This statute raises the age of consent to 18 in particular cireum-stances. When the legislature amended AS 11.41.4838 in 1990 to make it a crime for certain adults to engage in sexual penetration with 16- and 17-year-olds, the legislature omitted "same household" adults and included only "position of authority" adults. Thus, the legislature obviously thought that there was a substantive difference between these two groups, and the legislature intended for these two groups to be treated differently with regard to their sexual relations with 16- and 17-year-olds. "Position of authority" adults commit a crime when they engage in such conduct; "same household" adults do not.

(a) To wphold Wurthmamm's conviction for third-degree sexual abuse, the majority has been forced to re-write the definition of "position of authority"

Wurthmann is clearly a "same household" adult,. For years, he lived in the same household as AL., and he had substantial authority over her; in essence, he was A.L.'s stepfather. But to be convicted of third-degree sexual abuse, Wurthmann had to be a "position of authority" adult.

So how does Wurthmann, a "same household" adult, become transformed into a "position of authority" adult? The majority's answer is that "same household" adults can gradually become "position of authority" adults, depending on how long they live in the household with the teenager and how much authority over the teenager they are given by the teenager's legal parent (or, alternatively, how much authority they arrogate for themselves, even without the parent's consent).

According to the majority, a live-in boyfriend's ascension to the status of "position of authority" hinges on "the dynamics of the household, the personalities of the individuals involved, and the amount of authority the legal or biological parent delegates". (Opinion, page 765) The majority declares that

[a] roommate, adult step-sibling, or live-in boyfriend might ... have only limited and intermittent authority over a child in the household. But a live-in boyfriend who assumes the position of a stepfather has additional influence by virtue of his status as a person of special trust in the child's life. [A live-in boyfriend can be deemed to occupy a "position of authority" if,] by virtue of [his] position in relation to the child ... [, he has] undue influence over a child.... [TJhis is a fact-bound inquiry appropriately left to the jury.

Opinion, pages 765-766.

Some might agree that it is good policy to forbid sexual relations between teenagers and any adult who, because of "the dynamics of the [relationship and] the personalities of the individuals involved", comes to exercise "undue influence" over the teenager. But that is not the law the legislature wrote. AS 1141.470(5) does not define "position of authority" in terms of the psychological strengths and weaknesses of the parties, or the dynamics of their relationship. Rather, the statute contains a list of professional and quasi-professional roles that might give an adult undue influence over a teenager. "De facto stepparent" is not among this list.

Conversely, if an adult does perform one of the roles listed in AS 11.41.470(5), the statute does not require proof that this adult actualty exercised undue influence over the teenager-"undue influence" as determined by "the dynamics of [their relationship]" and "the personalities of the individuals involved". Rather, the adult's professional or quasi-professional role, by itself, conclusively establishes that the adult occupies a "position of authority".

(b) Not only has the majority re-written the definition of "position of authority", but they have done it badly

Not only has the majority effectively rewritten the definition of "position of authority", but they have drafted a legal standard so vague that it practically invites unequal application. According to the majority, the *771question of whether an adult occupies a "position of authority" must be answered by determining whether that adult is in a position to exercise "undue influence" over the teenager by virtue of the adult's status "as a person of special trust in the child's life." This status, the majority declares, is to be determined by assessing the "dynamics" of the relationship between the adult and the teenager, as well as "the personalities of the individuals involved".

There is nothing in the majority's definition that requires the adult to be living in the same household as the teenager, nor is there anything in this definition that requires proof that the adult fills one of the professional or quasi-professional roles listed in AS 1141.470(5), or any other role substantially similar to those listed. The test has become "undue influence", pure and simple Or rather, not so simple.

The majority asserts that "undue influence" is a "fact-bound issue" that juries should decide. But what standard is a jury to use? The majority says that the idea is to identify adults who occupy a position of "special trust", given the "personalities" of the adult and the teenager and the "dynamics" of their relationship. But these generalities do not provide much guidance to a jury seeking to decide whether a particular defendant occupied a position of authority with respect to a particular teenager. Nor do these generalities provide much guidance for trial judges who will inevitably have to draft jury instructions and answer jury questions about what this test means.

I fear that such a hazy and subjective legal test will only encourage juries to convict a defendant when they perceive him as predatory and, conversely, acquit a defendant when they perceive the teenager as sexually aggressive. This is not good law and, more important, it is not what the legislature had in mind.

(c) In addition, the majority's interpretation of "position of authority" makes the legislature's "same household" provisions redundant

The majority concludes that the term "position of authority" applies to any adult who exercises authority comparable to the authority enjoyed by the groups of adults listed in AS 11.41.470(5). But this is a misreading of AS 1141470(5). This statute does not say that an adult will be deemed to occupy a "position of authority" if the adult exercises authority that is substantially similar to the types of authority exercised by the listed groups. Rather, the statute says that an adult will be deemed to occupy a "position of authority" if the adult occupies a position that is substantially similar to the professional and quasi-professional positions listed in the statute. When the statute refers to adults who occupy a "substantially similar position", the statute is speaking of adults who occupy similar professional or quasi-professional roles-and not, as the majority apparently concludes, all adults who might exercise equal or greater authority over a child.

The problem with the majority's interpretation of the statute becomes clearer if one examines the groups of adults who are listed in AS 11.41.470(5) as occupying "positions of authority". The statute lists employers, youth leaders, scout leaders, coaches, teachers, counselors, school administrators, religious leaders, doctors, nurses, psychologists, guardians ad litem, and babysitters. Generally speaking, these adults have only limited contact with, and only intermittent authority over, the children that they deal with in their professional or quasi-professional roles.

Except in the case of "babysitters" (a term that could conceivably encompass people who provide all-day child care, five days a week), it appears that any adult in the legislature's "same household" category-that is, any adult who resides in the same household as the child and who has been granted authority over the child-will generally have an equal or better opportunity to pressure or manipulate a child into sexual activity than the groups of adults listed in the "position of authority" statute. For instance, it is difficult to imagine what kind of authority a household member might exercise over a child that would be less than the degree of authority exercised by a doctor or nurse who might see the child twice a year for half an hour, or by a babysitter who is hired to *772spend an evening with the child onee every month or two.

If, as the majority appears to hold, an adult must be deemed to occupy a "position of authority" as long as the adult exercises the same minimal amount of control over a child that characterizes such professionals and quasi-professionals, then essentially every adult who lives in the same household as a child and who exercises authority over the child will occupy a "position of authority" in relation to that child-for any such adult will certainly have at least the same limited degree of contact with the child, and the same cireumseribed supervisory authority over the child, that characterizes the people listed in AS 11.41.470(5).

For this reason, the majority's interpretation of the "position of authority" statute violates one of the primary rules of statutory construction: that a court should assume that the legislature did not enact redundant or useless statutes. If two or more related statutory provisions arguably apply to a particular set of circumstances, a court should assume that the legislature intended these statutory provisions to mean different things. "One of the prime directives of statutory construction is to avoid interpretations that render parts of a statute "inoperative or superfluous, void or insignificant."4 Courts must presume that, if the legislature saw fit to enact two or more separate statutory provisions dealing with the same problem or issue, the legislature must have believed that each provision was necessary-and, thus, that each provision applied to a different aspect of the problem or issue.

Under the majority's expansive interpretation of "position of authority", there would be no need for the legislature to enact separate provisions to prohibit sexual activity between children and the adults who reside with them and exercise authority over them. Any such adults would occupy "positions of authority". This indicates that the majority's interpretation of the statute is incorrect.

(d) The majority's interpretation of "position of authority" appears to be at odds with the legislative history of the sexual abuse statutes

I acknowledge that there is a certain moral force behind the majority's decision to hold Wurthmann guilty of third-degree sexual abuse. Because of his long-term relationship with A.L.'s mother, Wurthmann assumed the role of AL's de facto stepfather. Thus, Wurthmann's real authority over AL. was more expansive and continuous than the types of authority exercised by the groups of adults listed in AS 11.41.470(5), the statute defining "position of authority". From this, the majority concludes that Wurthmann's role in A.L.'s life must have amounted to a "position of authority". "[IJt would be unreasonable," the majority asserts, to think that the legislature "inten[{ded] to impose criminal liability on a babysitter or teacher but not a live-in boyfriend who assumes the role of a stepfather and is even better positioned to manipulate a child in his care." (Opinion at 766)

But the legislative history of the sexual abuse statutes does indeed offer good reason to think that the legislature knew what they were doing, and made a purposeful choice, when they raised the age of consent to 18 for adults in positions of authority but kept the age of consent at 16 for adults who live in the same household and exercise authority over a teenager.

The "same household" provisions-i.e., the amendments to the first- and second-degree sexual abuse statutes that increased the penalties for adults who engage in sexual activity with teenagers if they live in the same household as the teenager and exercise authority over the child-were enacted in 1988. The declared purpose of these 1988 amendments was to treat live-in boyfriends more like stepfathers when they engaged in sexual activity with teenagers under their authority.

Prior to 1988, a stepfather who engaged in sexual relations with a 13-, 14-, or 15-year, old stepchild was guilty of an unclassified felony (first-degree sexual abuse), but a live-*773in boyfriend who engaged in similar sexual activity with his girlfriend's child was treated like any other adult; that is, he was guilty of only a class B felony (second-degree sexual abuse). The 1988 amendments increased the punishment for sexual activity between an adult and a child under the age of 16 years if the adult was "residing as a member of the social unit in the same household as the [victim] and if the adult exercised authority over the child. In other words, the amended law applied to adults who functioned as de facto members of the teenager's family.

However, the legislature did not completely eliminate the disparity between stepfathers and live-in boyfriends. For stepparents, the legislature raised the age of consent to 18. That is, stepparents were guilty of sexual abuse (in either the first or second degree) if they engaged in sexual activity with stepchildren under the age of 18. But for live-in boyfriends-even live-in boyfriends who function exactly like stepfathers-the legislature expressly decided to leave the age of consent at 16.

In the letter of intent that accompanied the 1988 amendments, the House Judiciary Committee declared that 16 years of age, rather than 18, should be the cut-off point for a live-in boyfriend's eriminal liability:

The addition of AS 11.41.4834(a)(8) ... recognizes that the most serious forms of child sexual abuse are often committed by those who live in the same household as the victim or who are temporarily entrusted with the victim's care.
Despite having no legal authority over the victim, such persons are nonetheless in a position of power such that even older children often find it impossible to thwart their advances.... [Thhe new changes apply only to victims from 18 to 15 years old. The cutoff at 16 years of age was specifically chosen instead of the 18-year-old cutoff in other subsections dealing with persons with legal or biological ties to the victim.

1988 House Journal 2331.

Thus, the legislature understood that the new law would create a discrepancy between the criminal Hability of stepparents and the criminal liability of live-in boyfriends. The age of consent for stepparents would be 18, while the age of consent for live-in boyfriends would be 16. Assistant Attorney General Dean J. Guaneli told the House Judiciary Committee that this disparate treatment "was a judgment call" by the law's drafters. He explained, "[WJlith certain types of offenders, such as a parent or legal guardian, it may not be possible for someone sixteen or seventeen years of age to avoid the advances of [such an] adult, so it is appropriate to prohibit sexual [activity between them] up to age 18. [But with] a live-in boyfriend[,] ... it may not be the same." 5

There is no similar letter of intent to explain the legislature's purpose when they amended the definition of third-degree sexual abuse in 1990. But the legislature's action can reasonably be construed as a purposeful continuation of the policy they adopted in 1988-the policy that the age of consent should remain at 16, even when an adult lives in the same household as the teenager and exercises authority over the child.

In the first- and second-degree sexual abuse statutes, "same household" adults and "position of authority" adults are treated exactly the same. (In fact, the "same household" and the "position of authority" provisions appear as linked pairs in both statutes.) With respect to both groups, the first- and second-degree sexual abuse statutes do not alter the normal age of consent; i.e., the age of consent remains at 16. But the statutes impose a more severe penalty on "same household" and "position of authority" adults for sexual activity that is already eriminal for other adults-sexual activity with teenagers between the ages of 13 and 16.

The third-degree sexual abuse statute is different. It raises the age of consent to 18, thus punishing sexual activity that would not be criminal for other adults-sexual penetration with a 16- or 17-year-old. The legislature wrote this statute so that "position of authority" adults commit third-degree sexual abuse when they engage in such conduct, but "same household" adults do not.

*774My colleagues can not find any conceivable rationale for the legislature's action, at least when the "same household" adult exercises the same kind of authority (or greater authority) than the adults who pursue the professions and quasi-professions listed in AS 11.41.470(5). But one could reasonably argue that the wording of the third-degree sexual abuse statute simply re-confirms the legislature's 1988 policy decision not to raise the age of consent for "same household" adults.

The majority suggests that there is little to recommend this policy. Be that as it may, it is the legislature's role to set policy, and it is this court's role to interpret statutes as the legislature intended. The legislature consciously chose not to raise the age of consent for "same household" adults when they created that category of offender in 1988. Although the matter obviously can be debated, there is good reason to believe that the legislature was simply following that same policy when, in 1990, they wrote the third-degree sexual abuse statute to exclude "same household" adults.

Ambiguous criminal statutes must be interpreted against the government.6 Thus, Wurthmann does not have to convincingly prove that this is exactly what the legislature was thinking when they wrote the third-degree sexual abuse statute to include "position of authority" adults while at the same time excluding "same household" adults. Rather, it is the State's (and the majority's) burden to show that Wurthmann's interpretation of the legislature's actions is untenable. I do not believe that this interpretation of the legislative history is untenable, and I therefore conclude that this court has a duty to interpret the statute in Wurthmann's favor.

Conclusion

For the reasons explained here, I conclude that the majority has wrongly construed the definition of "position of authority" codified in AS 11.41.470(5). Although Wurthmann lived in the same household as AL. and exercised substantial authority over her, Wurthmann did not occupy a "position of authority" in relation to AL.. I therefore conclude that Wurthmann could not legally be convicted of third-degree sexual abuse of a minor.

. See AS 11.41.434(a)(3)(A) (first-degree sexual abuse of a minor) and AS 11.41.436(a)(5)(A) (second-degree sexual abuse of a minor).

. Compare AS 11.41.434(a)(3) with AS 11.41.436(a)(1).

.Compare AS 11.41.436(a)(5) with AS 11.41.438(a)(1).

. Champion v. State, 908 P.2d 454, 464 (Alaska App.1995) (quoting 22,757 Square Feet, more or less v. State, 799 P.2d 777, 779 (Alaska 1990)).

. Minutes of the House Judiciary Committee, January 26, 1988: hearing on House Bill 237.

. See Wells v. State, 706 P.2d 711, 713 (Alaska App.1985) ("It is well established that ... ambiguities in penal statutes must be resolved in favor of the accused.").