State Of Louisiana v. Aaron Wayne Bush

CourtLouisiana Court of Appeal
DecidedDecember 30, 2020
Docket2020KA0259
StatusUnknown

This text of State Of Louisiana v. Aaron Wayne Bush (State Of Louisiana v. Aaron Wayne Bush) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Of Louisiana v. Aaron Wayne Bush, (La. Ct. App. 2020).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

NO. 2020 KA 0259

VERSUS

AARON WAYNE BUSH

Judgment Rendered: DEC 3 0 2020

On Appeal from the 22nd Judicial District Court Parish of St. Tammany, State of Louisiana No. 615308

The Honorable Scott Gardner, Judge Presiding

Warren L. Montgomery Counsel for the State of Louisiana District Attorney J. Bryant Clark, Jr. Assistant District Attorney Covington, Louisiana

Richard A. Tonry, II Counsel for Defendant/ Appellant Slidell, Louisiana Aaron Wayne Bush

BEFORE: HIGGINBOTHAM, THERIOT, AND WOLFE, JJ. WOLFE, I

The defendant, Aaron Wayne Bush, was charged by bill of information with

operating a vehicle while intoxicated, third offense, a violation of La. R.S. 14: 98( A)

and La. R. S. 14: 98. 3. After the trial court denied his motion to quash, the defendant

withdrew his original not -guilty plea and pled guilty as charged pursuant to State v.

Crosby, 338 So. 2d 584 ( La. 1976). The trial court sentenced the defendant to five

years imprisonment at hard labor, suspended said sentence, and imposed five years

of supervised probation with special conditions.' The defendant now appeals,

challenging the trial court' s denial of his motion to quash.2 We affirm the conviction

and sentence.

FACTS

The defendant pled guilty; therefore, there was no trial to develop the facts of the offense. Further, at the guilty plea hearing, the State did not present any facts,

as the parties stipulated to the existence of a factual basis for the offense based on

pretrial discovery and discussions. The bill of information states that on or about

February 9, 2019, the defendant committed the instant offense " by operating a motor

vehicle while under the influence of alcohol or any scheduled controlled dangerous

substance or while under the influence of alcohol and one or more drugs which is

not a scheduled controlled dangerous substance." The bill of information further

states that this is a third offense, the defendant having previously been convicted of

The special conditions included that the defendant: ( 1) serve 75 days in parish jail; ( 2) complete the sobriety court program ofthe 22nd Judicial District Court; (3) pay a fine of $2, 000. 00; 4) obtain a substance abuse evaluation and comply with any treatment recommendations; ( 5) complete a substance abuse program; ( 6) complete a driver -improvement program; and ( 7) refrain from operating a vehicle unless authorized by the court.

2 At the time of his Crosby plea, the defendant did not state the specific adverse ruling he wished to appeal; therefore, appellate review is limited to evidentiary rulings that " go to the heart of the prosecution' s case." See State v. Joseph, 2003- 315 ( La. 5/ 16/ 03), 847 So. 2d 1196, 1197 per curiam). The only adverse ruling reflected in the record is the trial court' s denial of the motion to quash, which goes to the heart of the prosecution' s case. Thus, the denial of the motion to quash is reviewable on appeal.

2 operating a vehicle while intoxicated on June 13, 2013, in Picayune Municipal

Court, State of Mississippi under docket number MC 12- 04977, and on January 23,

2014,3 in First Parish Court of Jefferson Parish under docket number F 1944265.

DISCUSSION

In his sole assignment of error, the defendant contends that his motion to

quash should have been granted as to the Mississippi predicate conviction. He notes

that the State only introduced a one-page, uncertified document entitled, " Uniform

Municipal Court Case Criminal Record State of Mississippi Pearl River County,"

introduced into evidence as " State' s Exhibit 1" and marked as " S 1." He argues that

the trial court erred in considering the Mississippi appellate pleading when no

documentary evidence of an appeal was introduced into evidence at the motion to

quash hearing, noting that courts cannot take judicial notice of records from other

courts. He argues that Exhibit S1 is " woefully deficient" and does not satisfy the

State' s initial burden of proving the existence of the Mississippi predicate. He notes

that Exhibit S 1 does not indicate that he knowingly and voluntarily waived each of

his Boykin rights,' that he was ever adjudicated guilty, or that his plea was accepted

by the court. He further notes that in State v. Longo, 560 So.2d 530, 533 ( La. App.

1st Cir. 1990), this court rejected the use of pre- printed forms like Exhibit SI to

prove a knowing waiver of constitutional rights. Finally, the defendant argues that

pursuant to State v. Parker, 2019- 0028 ( La. 10/ 22/ 19), 285 So. 3d 1041, 1044 (per

curiam), his burden to produce affirmative evidence was met due to the lack of any

reference to his Boykin rights in Exhibit S 1, shifting the burden back to the State to

produce a perfect transcript, which he contends the State failed to do.'

3 The bill of information inadvertently states " 2104" as the year of the Jefferson Parish conviction.

4 Boykin v. Alabama, 395 U.S. 238, 243, 89 S. Ct. 1709, 1712, 23 L.Ed.2d 274 ( 1969).

5 The defendant is not challenging the Louisiana predicate conviction on appeal. 3 Prior convictions may be proved by any competent evidence. State v. White,

2013- 1525 ( La. 11/ 8/ 13), 130 So. 3d 298, 300 ( per curiam). Various methods may

be used to prove that the defendant on trial is the same person whose name is shown

as the defendant in the evidence of a prior conviction, such as: the testimony of

witnesses; expert opinion comparing the accused' s fingerprints with those of the

person previously convicted; photographs contained in a duly authenticated record;

or evidence of identical driver' s license number, sex, race, and date of birth. State

v. Dahlem, 2013- 0577 ( La. App. 1 st Cir. 6/ 18/ 14), 148 So. 3d 591, 597- 98, affd,

2014- 1555 ( La. 3/ 15/ 16), 197 So. 3d 676. Herein, the documentary evidence of the

Mississippi predicate reflects that the defendant, identified by the identical full

name, identical date of birth, and matching social security number as provided in the

bill of information for the instant case, pled guilty to a DWI offense committed on

September 11, 2012.6

A guilty plea is a conviction and, therefore, should be afforded a great measure

of finality. A presumption of regularity attaches to prior convictions in multiple

offender DWI cases, and the burden is on the defendant to show the prior guilty plea

is constitutionally deficient. A motion to quash is the proper vehicle to attack the

constitutionality of prior convictions used to enhance a DWI charge. State v.

Petersen, 2017- 1498 ( La. App. 1st Cir. 4/ 6/ 18), 2018WL1663047, * 2.

For a misdemeanor guilty plea to be used as a basis for actual imprisonment,

enhancement of actual imprisonment, or conversion of a subsequent misdemeanor

into a felony, the trial judge must inform the defendant that by pleading guilty he

waives his privilege against compulsory self-incrimination, his right to trial and jury

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Related

Boykin v. Alabama
395 U.S. 238 (Supreme Court, 1969)
State v. Crosby
338 So. 2d 584 (Supreme Court of Louisiana, 1976)
State v. Deville
879 So. 2d 689 (Supreme Court of Louisiana, 2004)
State v. Cadiere
754 So. 2d 294 (Louisiana Court of Appeal, 2000)
State v. Balsano
11 So. 3d 475 (Supreme Court of Louisiana, 2009)
State v. Shelton
621 So. 2d 769 (Supreme Court of Louisiana, 1993)
State v. Stewart
656 So. 2d 677 (Louisiana Court of Appeal, 1995)
State v. Joseph
847 So. 2d 1196 (Supreme Court of Louisiana, 2003)
State v. Smith
766 So. 2d 501 (Supreme Court of Louisiana, 2000)
State v. Lozier
375 So. 2d 1333 (Supreme Court of Louisiana, 1979)
State Ex Rel. Jackson v. Henderson
255 So. 2d 85 (Supreme Court of Louisiana, 1971)
State v. Verdin
845 So. 2d 372 (Louisiana Court of Appeal, 2003)
State v. Clesi
967 So. 2d 488 (Supreme Court of Louisiana, 2007)
State v. Longo
560 So. 2d 530 (Louisiana Court of Appeal, 1990)
State v. Carlos
738 So. 2d 556 (Supreme Court of Louisiana, 1999)
State v. Jones
404 So. 2d 1192 (Supreme Court of Louisiana, 1981)
State v. Alvarez
78 So. 3d 265 (Louisiana Court of Appeal, 2011)
State of Louisiana v. Gerald W. Dahlem
197 So. 3d 676 (Supreme Court of Louisiana, 2016)
State v. White
130 So. 3d 298 (Supreme Court of Louisiana, 2013)
State v. Morgan
134 So. 3d 1160 (Supreme Court of Louisiana, 2014)

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