Samuels v. Commonwealth

COLEMAN, Judge.

Larry E. Samuels was convicted of driving on a suspended license, see Code § 46.2-301, and driving a motor vehicle while under the influence of alcohol (DUI) as a third offense. See Code §§ 18.2-266 and 18.2-270. Samuels contends the trial judge erred by admitting into evidence a 1987 DUI conviction order to prove a third offense and to enhance punishment. See Code § 18.2-270. He asserts that the 1987 conviction order was inadmissible because the Commonwealth failed to prove that he was represented by counsel at the 1987 proceeding. Finding no error, we affirm the conviction.

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