AI Generated Opinion Summaries

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 was found behind the wheel of a car, wearing only boxer shorts, after driving onto a curb. A blood test revealed a blood alcohol content of 0.19% and trace amounts of cocaine metabolites. The Defendant had at least eight prior DWI convictions, including two felony DWIs, and his driver’s license had been revoked for 100 years in 1994 (paras 3-4).

Procedural History

• District Court, (N/A): The Defendant pleaded no contest to a felony DWI (fourth or subsequent offense) and driving on a revoked license. The court sua sponte aggravated the maximum felony DWI sentence by one-third, resulting in a total sentence of three years minus one day (paras 1, 4).

Parties' Submissions

• Defendant-Appellant: Argued that the sentence enhancement violated legislative intent as recognized in State v. Anaya, infringed on the separation of powers, constituted double enhancement in violation of double jeopardy principles, deprived him of due process, and contravened the U.S. Supreme Court’s decision in Apprendi v. New Jersey (para 1).
• Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

• Whether the district court erred in sua sponte enhancing the Defendant’s felony DWI sentence under the aggravation statute.
• Whether the enhancement violated legislative intent, double jeopardy principles, due process, or the U.S. Supreme Court’s decision in Apprendi v. New Jersey.

Disposition

• The Court of Appeals reversed the district court’s enhancement of the Defendant’s sentence and remanded the case for further proceedings (para 12).

Reasons

Per Fry J. (Sutin and Castillo JJ. concurring):

• The Court relied on the reasoning in State v. Anaya, which held that the legislature did not intend to treat DWI felonies like other fourth-degree felonies for sentencing purposes. The DWI statute is "self-enhancing," and the legislature only intended to increase the penalty for a fourth or subsequent DWI offense to 18 months, without further enhancement under other statutes (paras 2, 6-7).
• The Court applied the rule of lenity, resolving statutory ambiguities in favor of the Defendant. Neither the DWI felony statute nor the aggravation statute explicitly allowed for enhancement of DWI felony sentences (paras 7-9).
• The Court distinguished the aggravation statute from the habitual offender statute analyzed in Anaya but concluded that the same reasoning applied, regardless of the severity of the enhancement (para 10).
• The Court acknowledged the district court’s frustration with the Defendant’s recidivism but emphasized that it is the legislature’s role to create penalties for repeat offenders (para 11).