State v. WilsonAnnotate this Case
The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming Defendant's conviction for operating a vehicle under the influence of an intoxicant, holding that the ICA did not err in its ultimate conclusion that a colloquy was not required in this case before the trial court accepted the stipulation entered into between defense counsel and the State as to the arresting police officer's training and qualifications to conduct standardized field sobriety tests.
The Supreme Court affirmed the ICA's judgment on appeal and the district court's judgment but upon the reasons set forth in this opinion. The Court held that while the ICA correctly held that a colloquy was not required in this case, it erred in setting forth an alternative holding that employed a novel test for evaluating prejudice resulting from a trial court's acceptance of a stipulation without a colloquy. The Court further provided guidance as to the proper allocation of authority between a defendant and defense counsel in light of the ICA's statements regarding defense counsel's authority to stipulate to an evidentiary matter based on trial "tactics and procedure."