Hunt v. State

487 N.E.2d 1330, 1986 Ind. App. LEXIS 2260
CourtIndiana Court of Appeals
DecidedJanuary 23, 1986
Docket2-1084A325
StatusPublished
Cited by13 cases

This text of 487 N.E.2d 1330 (Hunt v. State) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hunt v. State, 487 N.E.2d 1330, 1986 Ind. App. LEXIS 2260 (Ind. Ct. App. 1986).

Opinions

SHIELDS, Judge.

On October 31,1983, David Hunt pleaded guilty to driving under the influence of intoxicating liquor.1 He filed a “Petition for Post-Conviction Relief on April 23, 1984, alleging he did not knowingly and intelligently relinquish his constitutional rights. He now appeals the trial court’s refusal to vacate his guilty plea and presents four issues for review. Those issues, restated for clarity, are:

1. Whether the trial court’s findings of fact are sufficiently specific;
2. Whether the post-conviction relief court erred in concluding Hunt knowingly and intelligently waived his constitutional rights;
3. Whether a defendant pleading guilty to a misdemeanor traffic offense must be advised of enumerated constitutional rights pursuant to Ind. Code Ann. § 9-4-7-92 (Burns Supp. [1332]*13321985) or Ind.Code Ann. § 35-35-1-2(a)3 (Burns Supp.1983) or both; and
4. Whether Ind.Code Ann. § 35-35-1-2(b) is unconstitutional.

On August 24, 1983, on the south side of Indianapolis, Hunt was seen by Rick Davis, a Marion County Deputy Sheriff, driving his car erratically and over ninety miles per hour. When the officer was eventually able to stop Hunt, he noticed Hunt smelled of alcohol and exhibited other signs of intoxication. Hunt was transported to Wish-ard Hospital and given a breathalyzer test. The results indicated Hunt had a blood alcohol content of .16%. On October 31, 1983, Hunt signed a court prepared form containing the constitutional rights listed in I.C. § 35-35-1-2 and pleaded guilty to the charge of driving under the influence of intoxicating liquor. The judge asked Hunt if his signature was at the bottom of the form, but asked no further questions concerning Hunt’s understanding of the constitutional rights he was waiving.

I.

Hunt first asserts the findings of fact and conclusions of law entered by the post-conviction hearing judge are inadequate.4 However, the lack of detail and specifity in the post-conviction court’s findings do not present an obstacle in our review in this ease. Therefore, we will not remand this ease to the trial court for more specific findings. Lowe v. State, 455 N.E.2d 1126 (Ind.1983); Moffett v. State, 398 N.E.2d 686 (Ind.App.1979).

II.

Hunt contends the post-conviction court erred in concluding he knowingly and intelligently waived his constitutional rights. We agree, and reverse on this ground.

[1333]*1333We must begin our discussion with reference to Boykin v. Alabama, 395 U.S. 238, 89 S.Ct. 1709, 23 L.Ed.2d 274 (1969), the fountainhead of constitutional advisement law. Boykin lists three federal constitutional rights of which a defendant must be aware and understand in order for his waiver of those rights by a plea of guilty to be constitutionally permissible: the right to confront one’s accusers, Pointer v. Texas, 380 U.S. 400, 85 S.Ct. 1065, 13 L.Ed.2d 923 (1965); the right to trial by jury, Duncan v. Louisiana, 391 U.S. 145, 88 S.Ct. 1444, 20 L.Ed.2d 491 (1968); and the privileges against compulsory self-incrimination, Malloy v. Hogan, 378 U.S. 1, 84 S.Ct. 1489, 12 L.Ed.2d 653 (1964). 395 U.S. at 243, 89 S.Ct. at 1712.

Boykin concerned a felony case, as did Pointer, Duncan and Malloy. There is, therefore, a preliminary inquiry as to whether the Boykin rights attach to persons accused of misdemeanors. As a matter of federal constitutional law, the right to trial by jury and the privilege against self-incrimination have been specifically extended to persons accused of misdemeanors. In Baldwin v. New York, 399 U.S. 66, 90 S.Ct. 1886, 26 L.Ed.2d 437 (1970), the Court held the right to trial by jury exists where there is a possibility of receiving more than a six month sentence, and in Berkemer v. McCarty, 468 U.S. 420, 104 S.Ct. 3138, 82 L.Ed.2d 317 (1984), the Court held a person suspected of a misdemeanor traffic offense must be given Miranda warnings prior to a custodial interrogation the same as a person suspected of a felony.

Although the United States Supreme Court has not specifically extended application of Pointer v. Texas to misde-meanants, at least two states have addressed the issue and concluded persons accused of committing a misdemeanor are entitled to the right of confrontation. See Mills v. Municipal Court, 10 Cal.3d 288, 110 Cal.Rptr. 329, 515 P.2d 273 (1973); and Mosley v. Gorfinkel, 81 Misc.2d 998, 367 N.Y.S.2d 155 (N.Y.Supp.1975). We agree. Logic demands the right of confrontation be applicable to trials of persons accused of misdemeanors. “There are few subjects, perhaps, upon which the Court and other courts have been more nearly unanimous than in their expressions of belief that the right of confrontation and cross-examination is an essential and fundamental requirement for the kind of fair trial which is this country’s constitutional goal.” Pointer, 380 U.S. at 405, 85 S.Ct. at 1068.

As a matter of state law, the Indiana Constitution in Article 1, section 13 provides, “In all criminal prosecutions, the accused shall have the right to a public trial, by an impartial jury, in the county in which the offense shall have been committed; to be heard by himself and counsel; to demand the nature and cause of the accusation against him, and to have a copy thereof; to meet the witnesses face to face, and to have compulsory process for obtaining witnesses in his favor.” (emphasis added) Gillespie v. Gilmore, 159 Ind.App. 449, 307 N.E.2d 480 (1974) held a distinction cannot be made between felonies and misdemeanors as regards the right to trial by jury in view of the language, “in all criminal prosecutions,” and Bolkovac v. State, 229 Ind. 294, 98 N.E.2d 250 (1951), relying on the same constitutional language, stated the right to counsel in misdemeanor cases exists to the same extent as in felony cases. Because the language “in all criminal prosecutions” precedes all rights enumerated in section 13, it is only logical that the right of confrontation also applies to misdemeanor cases. We thus conclude the rights enumerated in Boykin v. Alabama are applicable to persons accused of misdemeanors as a matter of state and federal constitutional law.

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Bluebook (online)
487 N.E.2d 1330, 1986 Ind. App. LEXIS 2260, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hunt-v-state-indctapp-1986.