State v. Arrington

The Supreme Court reversed the decision of the court of appeals concluding that Defendant’s stipulation to a certain type of second-degree murder was an improper stipulation, holding that Defendant properly stipulated to the facts underlying his conviction and the conviction itself.As part of a plea agreement, Defendant stipulated to the sentencing worksheet showing his prior offenses, one of which was a second-degree murder conviction designated as a B1 offense. In so stipulating, Defendant acknowledged that the factual basis of his conviction involved general second-degree murder, a B1 classification, and did not implicate the exception for less culpable conduct involving an inherently dangerous act or omission or a drug overdose, a B2 classification. The court of appeals vacated the trial court’ judgment and set aside Defendant’s guilty plea, concluding that Defendant improperly stipulated to a matter of “pure legal interpretation.” The Supreme Court reversed, holding (1) Defendant’s stipulation was properly understood to be a stipulation to the facts of his prior offense, and those facts supported the offense’s B1 classification; and (2) the trial court properly accepted the stipulation. View "State v. Arrington" on Justia Law