STATE OF MISSOURI, Plaintiff-Respondent v. WILLIAM ALBERT RATTLES
2014 Mo. App. LEXIS 1104
| Mo. Ct. App. | 2014Background
- Defendant William A. Rattles was convicted of driving while intoxicated (DWI) and driving while revoked.
- Trooper Creasey observed signs of intoxication and that Rattles admitted consuming alcohol, cannabis, and Valium after an unrelated accident.
- Rattles refused a breathalyzer when advised under implied-consent provisions.
- The State sought to prove Rattles was an aggravated offender under § 577.023 by admitting prior intoxication-related offenses.
- The State introduced DR-certified driving records and certified court documents to prove prior convictions; defense objected to certification and foundation but was overruled for limited admissibility.
- The trial court found beyond a reasonable doubt that Rattles had three or more intoxication-related offenses and sentenced him as an aggravated offender.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State proved three prior intoxication offenses to support aggravated offender status | Rattles's record shows three prior DWI offenses listed on DR record. | Exhibits did not clearly prove valid prior convictions or waiver of counsel. | Yes; DR records suffice to prove prior convictions for enhancement. |
Key Cases Cited
- State v. Miller, 153 S.W.3d 333 (Mo. App. S.D. 2005) (substantial evidence standard for prior offenses; use of records)
- State v. Lemons, 351 S.W.3d 27 (Mo. App. S.D. 2011) (evidence burden to prove prior intoxication offenses)
- State v. Craig, 287 S.W.3d 676 (Mo. banc 2009) (prior plea/finding not always required to prove prior offense)
- State v. Mitchell, 403 S.W.3d 614 (Mo. App. S.D. 2012) (DR records can prove prior convictions for enhancement)