In re Joseph S. Benoit v. (State of Vermont, Appellant)
Annotate this CaseThe issue presented for the Vermont Supreme Court's review in this interlocutory appeal centered on the available legal means for collaterally challenging a predicate conviction to an enhanced charge in light of two distinct lines of case law. Petitioner Joseph Benoit pled guilty to driving under the influence, third offense (DUI- 3), and subsequently challenged his underlying predicate convictions in a petition for post- conviction relief (PCR). The State sought summary judgment on the basis that by pleading guilty to DUI-3, petitioner waived his PCR challenges to any of the predicate convictions. The trial court denied summary judgment, concluding that Vermont case law required petitioner to raise his challenges in a post-sentencing PCR proceeding. The Supreme Court concluded defendant could raise collateral challenges to predicate convictions by preserving the challenge on the trial court record. The Supreme Court affirmed the denial of summary judgment on different grounds than the trial court, and remanded for the court to consider whether petitioner's waiver was knowing and voluntary.
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