Dexter v. State, 959 N.E.2d 235

Dexter was convicted of Class A felony neglect of a dependent and found to be a habitual offender, resulting in a 60-year sentence (30 base plus 30 enhancement).
The State sought habitual-offender enhancement based on prior felony convictions, including a 2000 theft conviction.
The State introduced an unsigned judgment of conviction to prove the 2000 conviction, plus other documentary and testimonial materials.
Dexter challenged the sufficiency of the evidence to prove the 2000 conviction, arguing the unsigned judgment and related materials were insufficient.
The Indiana Court of Appeals affirmed on all but the habitual-offender issue; the Supreme Court granted transfer to address the sufficiency of the habitual-offender proof.
The Supreme Court held the unsigned judgment is insufficient to prove a prior conviction beyond a reasonable doubt and that retrial on the habitual-offender enhancement is permissible.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an unsigned judgment proves a prior conviction beyond a reasonable doubt	State argued the unsigned judgment may be considered and is not void for irregularity	Dexter contends the unsigned judgment is insufficient to prove a prior conviction	Unsigned judgment is insufficient; insufficient probative value to sustain habitual-offender enhancement
What documentary evidence suffices to prove prior felonies for habitual enhancement	State relied on documentary records and testimony to prove the 2000 conviction	Dexter argued parol and non-documentary evidence cannot establish the conviction	Proper documentary records are required; parol evidence alone is insufficient
Whether retrial on a habitual-offender enhancement is barred by Double Jeopardy when the enhancement is reversed for insufficiency	State may retry to prove the enhancement	Retrial should be barred if the initial conviction was reversed for insufficiency	Retrial on the habitual-offender enhancement is permitted; not barred by Double Jeopardy

Morgan v. State, 440 N.E.2d 1087 (Ind. 1982) (require certified records to prove prior convictions for habitual offender)
Washington v. State, 441 N.E.2d 1355 (Ind. 1982) (parol evidence insufficient without authenticated records)
Beavers v. State, 566 N.E.2d 533 (Ind. 1991) (oral testimony considered with documentary evidence to identify defendant)
Powers v. State, 617 N.E.2d 545 (Ind. 1993) (certified records required; corroboration needed)
Jaramillo v. State, 823 N.E.2d 1187 (Ind. 2005) (recapitalization of Monge/Apprendi principles on recidivist enhancement)