Griswold v. Commonwealth

*479Opinion

ELDER, J.

Norman Edward Griswold appeals from his conviction under Code § 18.2-266 for driving under the influence of alcohol after having previously been convicted of a like offense. Appellant contends the trial court erred (1) in allowing the introduction of his uncounseled 1983 misdemeanor conviction in the sentencing phase; and (2) in finding that the evidence was sufficient to show that his 1985 conviction was counseled such that it was admissible during the guilt phase.

I

On August 3, 1992, appellant was charged with driving under the influence of alcohol under Code § 18.2-266 after…