AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Defendant was involved in a vehicle collision while under the influence of alcohol, resulting in his own serious injuries, including a ruptured aorta valve and a dislocated hip. The Defendant was found by an arresting officer in the right front seat of a truck that had collided with another vehicle, showing signs of great pain and injury. Two persons in the other vehicle were also injured, but their injuries were not the subject of the charge under Section 66-8-101(C) to which the Defendant pleaded guilty. The charge was based on the Defendant having caused great bodily harm to himself in the collision (paras 3, 7).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Appellant (Defendant): Argued that Section 66-8-101(C) does not apply to the perpetrator when the injury is self-inflicted and that the sentencing enhancements based on prior DWI convictions were improperly applied. The Defendant also contended that he was not properly informed of the sentencing enhancements at the plea stage, leading to an involuntary plea, and that the counsel and the court failed in their duties to advise him of the consequences of his plea (paras 1, 8-11).
• Appellee (State): Argued that the Legislature intended for Section 66-8-101(C) to include the perpetrator as a victim under the statute and that the Defendant was properly sentenced under the statute's enhancement provisions. The State also maintained that the statute is not ambiguous and that the Defendant's plea was voluntary and informed (paras 12-15, 19).

Legal Issues

• Whether Section 66-8-101(C) applies to a perpetrator who causes great bodily harm to himself while driving under the influence of intoxicating liquor.
• Whether the Defendant was improperly sentenced under Section 66-8-101(D) due to a misapplication of sentencing enhancements based on prior DWI convictions.
• Whether the Defendant's plea was involuntary due to failures by his counsel and the district court to advise him of the sentencing enhancements at the plea stage (paras 1-2, 8-11).

Disposition

• The Court held that Section 66-8-101(C) does not apply to the Defendant, the perpetrator, where the great bodily injury resulting from his unlawful conduct was to himself and not to others. Consequently, the judgment and sentence associated with the Defendant's plea were reversed and vacated.
• The Court also held that the Defendant was improperly sentenced under Section 66-8-101(D), as the enhancements were incorrectly applied.
• The Defendant is permitted to withdraw his plea (paras 2, 29).

Reasons

• Judges: JONATHAN B. SUTIN, MICHAEL D. BUSTAMANTE, J. MILES HANISEE concurred in the opinion authored by Judge SUTIN.
  The Court reasoned that the statutory language of Section 66-8-101(C) does not explicitly include the perpetrator as a victim and that the social policy embodied in criminal law does not support extending liability to self-inflicted injuries by DWI perpetrators. The Court also noted the absence of clear legislative intent to imprison DWI perpetrators for self-inflicted injuries.
  Regarding sentencing enhancements, the Court found that only prior DWI convictions within a ten-year period should enhance the basic sentence, contrary to the district court's application of enhancements for all prior convictions regardless of the time frame.
  The Court highlighted the failures of the defense counsel and the district court to inform the Defendant of the sentencing enhancements, which rendered his plea involuntary. The Court reiterated the obligations of lower courts and defense counsel in plea circumstances to ensure that a defendant's plea is knowing, intelligent, and voluntary (paras 12-24).