State v. Kuhlmann
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Appellant Brent Kuhlmann was convicted after a jury trial of domestic assault and test refusal. On appeal, Appellant argued that the trial court committed reversible error when it accepted a stipulation on elements of the charged offenses without advising him of his right to a jury trial on these elements and securing, either in writing or on the record, his personal waiver of the right to a jury trial on the stipulated elements. The court of appeals affirmed Appellant's convictions. The Supreme Court affirmed, holding (1) the trial court erred in failing to obtain Appellant's personal waiver of the right to a jury trial on the previous-conviction elements of the charged offenses; (2) the trial court's failure to obtain Appellant's personal waiver of his right to a jury trial did not amount to structural error; and (3) under the plain error standard, the error did not affect Appellant's substantial rights or the outcome of the case.
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