Reynard Eaglin v. District of Columbia, 123 A.3d 953

In 2013 Eaglin was charged in D.C. with DUI/OWI and reckless driving; the government sought enhanced sentencing under D.C. Code § 50-2206.13 based on a prior Maryland DUI.
In 2007 Eaglin pleaded guilty in Maryland and was placed on probation before judgment; he completed probation and never received a Maryland conviction or an order vacating his plea.
The D.C. statute imposes a mandatory minimum jail term for a current DUI when the defendant has a “prior offense,” defined to include “any guilty plea or verdict . . . for an offense under District law or a disposition in another jurisdiction for a substantially similar offense.”
The sole disputed question was whether Eaglin’s Maryland disposition (probation before judgment following a guilty plea) constitutes a qualifying “disposition in another jurisdiction” (i.e., a prior offense) under the D.C. statute.
The trial court found the Maryland guilty plea qualified as a prior offense; Eaglin pleaded guilty in D.C. and was sentenced with the enhancement; he appealed the enhanced sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a Maryland probation-before-judgment following a guilty plea is a qualifying “disposition in another jurisdiction” under D.C. Code § 50-2206.01(17)	Gov't: Eaglin’s guilty plea in Maryland is a qualifying disposition and thus a prior offense triggering D.C.’s enhancement	Eaglin: Because Maryland never entered a conviction (probation before judgment), he does not have a prior conviction/disposition for D.C. enhancement	Court held the Maryland guilty plea/probation-before-judgment is a qualifying “disposition” (prior offense), so the enhancement applies

District of Columbia v. Reid, 104 A.3d 859 (statutory interpretation reviewed de novo)
Peoples Drug Stores, Inc. v. District of Columbia, 470 A.2d 751 (en banc) (legislative intent found in statutory language)
Smith v. United States, 68 A.3d 729 (plain meaning controls absent absurdity)
Hood v. United States, 28 A.3d 553 (statutory construction principles)
Baltimore v. District of Columbia, 10 A.3d 1141 (holistic statutory interpretation)
Cook v. Edgewood Mgmt. Corp., 825 A.2d 939 (context required in statutory reading)
United States v. Deal, 508 U.S. 129 (word meaning drawn from context)
Berkley v. United States, 370 A.2d 1331 (assume legislature acted logically)
Abdulshakur v. District of Columbia, 589 A.2d 1258 (avoid implausible statutory results)
H.J. Inc. v. Northwestern Bell Telephone Co., 492 U.S. 229 (limited role of preambles)
Sun Oil Co. v. Wortman, 486 U.S. 717 (Full Faith and Credit Clause principles)
Thomas v. United States, 914 A.2d 1 (plain-error test for unpreserved appellate claims)