State v. Moe

WOLLE, Justice.

Defendant appeals from his conviction of second offense operating a motor vehicle while under the influence of intoxicants (OWI), an enhanced-punishment offense provided for in Iowa Code section 321.281 (1983). The trial court found that defendant’s 1980 conviction of first offense OWI could be used to raise to second offense status his 1984 conviction of OWI, because defendant had validly waived his right to counsel before entering a plea of guilty in 1980. Defendant contends that his conviction of OWI in 1980 could not be used for enhancement purposes because it was based on…