State v. Bruckner
Annotate this CaseDefendant pled guilty to a 2012 driving under the influence (DUI) charge. During a sentence enhancement hearing, the evidence showed Defendant had previously been convicted of DUI in 2003, 2001, and 1999. Defendant argued that the 1999 and 2001 convictions were the same convictions referred to in the 2003 enhancement hearing, and because those convictions did not result in enhancement of the 2003 charge, the State was collaterally estopped from using them for enhancement of the 2012 charge. The trial court found Defendant guilty of fourth-offense DUI, holding that the doctrine of collateral estoppel did not bar the use of two prior convictions for the purpose of sentence enhancement. The Supreme Court affirmed, holding that collateral estoppel did not bar the use of Defendant’s 1999 and 2001 DUI convictions as two of the three prior convictions necessary to enhance his 2012 conviction to fourth offense.
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