State v. JensenAnnotate this Case
Defendant William Jensen was charged with fourth offense driving under the influence. He filed a motion to strike one of his three prior driving under the influence convictions, arguing that because the magistrate court relied on a statement of rights form to establish the voluntariness of his guilty plea during that prior hearing, that prior conviction was invalid for sentence enhancement purposes. The trial court denied Jensen's motion to strike, concluding that the statement of rights form was an adequate record of voluntariness. Jensen appealed. The Supreme Court affirmed, holding (1) because Jensen did not demonstrate prejudice, his challenge to his prior driving under the influence conviction was not proper for the Court's consideration; and (2) Jensen did not demonstrate that the magistrate court's failure to personally canvass him to establish the voluntariness of his plea violated his due process rights.