Legal Opinion

State v. Brown

Court of Appeals of Minnesota

Decided March 21, 1984No. C1-83-1706, C6-83-1801PublishedCited by 6 opinions

1Opinion of the Court

OPINION

FOLEY, Judge.

The State appeals dismissal of gross misdemeanor DWI charges against defendants. The trial court held that defendants’ prior misdemeanor DWI convictions based on uncounseled guilty pleas may not be used to convert their current DWI offenses into gross misdemeanors because: 1) defendants did not validly waive their right to counsel, and 2) defendants were not informed of their rights in accordance with Minn.R.Crim.P. 15.02 or 15.03. We affirm. These cases are consolidated for a single opinion.

FACTS

Donald Brown and Craig Larson were each charged with violating Minn.Stat. §…

2Cases cited5 opinions

  1. Boykin v. AlabamaSupreme Court of the United States · 1969
  2. Carnley v. CochranSupreme Court of the United States · 1962
  3. State v. NordstromSupreme Court of Minnesota · 1983
  4. State v. MotlSupreme Court of Minnesota · 1983
  5. State v. MedenwaldtCourt of Appeals of Minnesota · 1984

3Cited by6 opinions

  1. State v. WilsonMissouri Court of Appeals · 1984
  2. State v. StewartCourt of Appeals of Minnesota · 1985
  3. State v. HansonCourt of Appeals of Minnesota · 1985
  4. State v. LyleCourt of Appeals of Minnesota · 1987
  5. State v. FoncesaCourt of Appeals of Minnesota · 1993

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