State v. D. Meyer
2017 MT 124
| Mont. | 2017Background
- Meyer was charged with Aggravated DUI under § 61-8-465, MCA; the statute makes several alternative aggravating elements (e.g., high BAC, ignition-interlock order, suspended license, refusal plus prior suspension, or prior DUI convictions).
- Meyer had two prior DUI convictions (one within ten years); he did not dispute their existence but moved in limine to exclude evidence of prior convictions under M. R. Evid. 403/404 and offered to stipulate to priors for sentencing only.
- Justice Court ruled that prior DUI conviction(s) are an element of Aggravated DUI and admitted Meyer’s certified driving record showing the prior convictions; the jury convicted Meyer of Aggravated DUI.
- Meyer appealed to District Court arguing priors were sentencing/recidivism matters (not elements) and that admitting priors was unduly prejudicial; District Court affirmed, holding priors are elements requiring jury finding.
- Supreme Court reviewed the record independently and affirmed: prior DUI convictions are elements of the offense that the State must prove beyond a reasonable doubt, and admission of the driving record was not impermissibly prejudicial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prior DUI convictions must be proven to a jury as an element of Aggravated DUI under § 61-8-465 | State: § 61-8-465 lists alternative elements; the applicable aggravator (priors) is an element the State must prove beyond a reasonable doubt | Meyer: Priors are recidivism/sentencing factors and need not be proven to a jury; he offered to stipulate for sentencing only | Held: Priors are statutory elements of the offense and must be proven to the jury beyond a reasonable doubt |
| Whether admitting certified driving record showing prior DUIs violated M. R. Evid. 403 (undue prejudice) | State: Driving record is probative because it establishes an element; limited details minimized prejudice | Meyer: Admission was highly prejudicial under Rules 403/404 and contributed to conviction | Held: Admission was proper; evidence was highly probative as an element and not impermissibly prejudicial |
Key Cases Cited
- Apprendi v. New Jersey, 530 U.S. 466 (2000) (facts increasing punishment beyond statutory maximum must be found by jury)
- Almendarez-Torres v. United States, 523 U.S. 224 (1998) (distinguishes elements from sentence-enhancing facts)
- State v. Weldele, 315 Mont. 452, 69 P.3d 1162 (Mont. 2003) (prior convictions used for sentence enhancement need not be proven to jury)
- State v. Root, 985 P.2d 494 (Ariz. 1999) (aggravation factor in aggravated DUI is an element for jury determination)
- State v. Swenson, 346 Mont. 34, 194 P.3d 625 (Mont. 2008) (admissible probative evidence in criminal trials is often prejudicial but not necessarily impermissible)