This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Defendant pleaded guilty to driving while intoxicated (DWI). The State sought to enhance the Defendant's sentence based on two prior convictions. The Defendant contested the validity of one of these prior convictions, arguing that it was uncounseled and therefore invalid.
Procedural History
- District Court of San Juan County: The court enhanced the Defendant's sentence based on the two prior convictions, finding that the prior conviction in question was valid and that the Defendant had been represented by counsel.
Parties' Submissions
- Defendant-Appellant: Argued that one of the prior convictions used to enhance his sentence was invalid because it was uncounseled. He claimed that the resulting sentence enhancement was illegal.
- Plaintiff-Appellee (State): Presented evidence of the prior conviction, including an order appointing counsel for the Defendant, and argued that the conviction was valid. The State contended that the Defendant failed to produce evidence supporting his claim that the prior conviction was uncounseled.
Legal Issues
- Was the Defendant's prior conviction invalid due to a lack of legal representation, thereby rendering the sentence enhancement illegal?
Disposition
- The Court of Appeals affirmed the district court's decision to enhance the Defendant's sentence.
Reasons
Per Bustamante J. (Wechsler and Sutin JJ. concurring):
The Court held that the State had met its burden of making a prima facie case that the Defendant had a prior conviction. The Defendant, in turn, was required to produce evidence supporting his claim that the prior conviction was uncounseled. However, the Defendant failed to provide any evidence beyond his assertion that the conviction was uncounseled, which the Court noted does not constitute evidence. The State provided proof of the prior conviction, including an order appointing counsel for the Defendant, and the district court found that the Defendant had been represented by counsel. The Court found no error in the district court's determination that the prior conviction was valid and upheld the sentence enhancement.