State of West Virginia v. Jay Folse

CourtWest Virginia Supreme Court
DecidedNovember 7, 2023
Docket21-0972
StatusPublished

This text of State of West Virginia v. Jay Folse (State of West Virginia v. Jay Folse) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of West Virginia v. Jay Folse, (W. Va. 2023).

Opinion

IN THE SUPREME COURT OF APPEALS OF WEST VIRGINIA

September 2023 Term _______________ FILED No. 21-0972 November 7, 2023 _______________ released at 3:00 p.m. EDYTHE NASH GAISER, CLERK SUPREME COURT OF APPEALS OF WEST VIRGINIA STATE OF WEST VIRGINIA, Plaintiff Below/Respondent,

v.

JAY FOLSE, Defendant Below/Petitioner.

Appeal from the Circuit Court of Monongalia County The Honorable Phillip Gaujot, Judge Case No. 21-MAP-12

REVERSED AND REMANDED WITH DIRECTIONS

Submitted: October 11, 2023 Filed: November 7, 2023

Jeremy B. Cooper, Esq. Patrick Morrisey, Esq. Blackwater Law PLLC Attorney General Aspinwall, Pennsylvania Michael R. Williams, Esq. Counsel for Petitioner Principal Deputy Solicitor General Mary Beth Niday, Esq. Assistant Attorney General Charleston, West Virginia Counsel for Respondent

CHIEF JUSTICE WALKER delivered the Opinion of the Court. SYLLABUS BY THE COURT

1. “‘In reviewing challenges to the findings and conclusions of the

circuit court, we apply a two-prong deferential standard of review. We review the final

order and the ultimate disposition under an abuse of discretion standard, and we review the

circuit court’s underlying factual findings under a clearly erroneous standard. Questions of

law are subject to a de novo review.’ Syl. Pt. 2, Walker v. West Virginia Ethics Commission,

201 W.Va. 108, 492 S.E.2d 167 (1997).” Syllabus Point 1, State v. Meadows, 231 W. Va.

10, 743 S.E.2d 318 (2013).

2. “A statute that is ambiguous must be construed before it can be

applied.” Syllabus Point 1, Farley v. Buckalew, 186 W. Va. 693, 414 S.E.2d 454 (1992).

3. “The primary object in construing a statute is to ascertain and give

effect to the intent of the Legislature.” Syllabus Point 1, Smith v. State Workmen’s

Compensation Commissioner, 159 W. Va. 108, 219 S.E.2d 361 (1975).

i WALKER, Chief Justice:

Petitioner Jay Folse pled no contest to obstructing an officer in 2019, without

counsel, in magistrate court. Later, Mr. Folse attempted to appeal the conviction to the

Circuit Court of Monongalia County under West Virginia Code § 50-5-13 (1994). But the

circuit court dismissed Mr. Folse’s appeal, reasoning that Mr. Folse’s no-contest plea in

magistrate court resolved the case and barred him from pursuing appellate review in circuit

court. On appeal, Mr. Folse contends that the circuit court erroneously dismissed his appeal

on the basis that he pled no contest in magistrate court. We agree. Under § 50-5-13(a),

“any defendant” may timely appeal a conviction in magistrate court to circuit court, save a

class of defendants specified in § 50-5-13(e)—a class to which Mr. Folse does not belong.

And § 50-5-13(a) and (b) afford a defendant such as Mr. Folse a trial de novo, to the circuit

court, without a jury. For those reasons, we reverse the circuit court’s order and remand

this case for further proceedings in accord with this Opinion.

I. FACTUAL AND PROCEDURAL BACKGROUND

On July 31, 2019, a criminal complaint was filed with the Magistrate Court

of Monongalia County alleging that Mr. Folse had violated West Virginia Code §§ 61-6-

1B (disorderly conduct), 61-5-17(a) (obstruction of an officer), and 61-3B-4 (trespassing)

in the course of attending a meeting of the Board of Governors of West Virginia University.

On December 17, 2019, Mr. Folse—then self-represented—entered into a plea agreement

in which he agreed to plead no contest to obstructing an officer in exchange for dismissal 1 of the two remaining charges and the State’s recommendation of a ninety-day jail sentence

(suspended) and two years’ unsupervised probation. Mr. Folse entered a no-contest plea

that same day. The magistrate accepted the no-contest plea, imposed the State’s

recommended sentence, and dismissed the disorderly conduct and trespassing charges.

Judgement orders reflecting Mr. Folse’s no-contest plea and dismissal of the disorderly

conduct and trespassing charges were also entered on December 17, 2019.

On January 12, 2021, Mr. Folse (again, self-represented) filed a “Motion for

Dismissal Due to Failure to Provide Speedy Trial [Three Term Rule].” According to Mr.

Folse, he had filed an appeal of his December 2019 conviction, but had not been tried in

the three, ensuing court terms. So, according to Mr. Folse, the magistrate was bound to

dismiss the case, with prejudice, under West Virginia Code § 62-3-21 (1959). 1 The State

responded that the magistrate court docket did not reflect that Mr. Folse had appealed from

1 West Virginia Code § 62-3-21 (1959) provides, in pertinent part, that,

every person charged with a misdemeanor before a justice of the peace . . . and who has therein been found guilty and has appealed his conviction of guilt and sentence to a court of record, shall be forever discharged from further prosecution for the offense set forth in the warrant against him, if after his having appealed such conviction and sentence, if after his having appealed such conviction and sentence, there be three regular terms of such court without a trial . . . .

Section 62-3-21 provides for exceptions to the effect of that rule. Mr. Folse represents that none of those exceptions apply to the present circumstances.

2 the December 2019 conviction, so he had not complied with Rule 20.1 of the West Virginia

Rules of Criminal Procedure for Magistrate Courts 2 and his three-term-rule argument was

meritless. 3 The magistrate court conducted a hearing on Mr. Folse’s motion on or about

March 2, 2021, but it is unclear whether the motion was ever ruled on. 4

On April 6, 2021, Mr. Folse filed a petition for a writ of mandamus in the

Circuit Court of Monongalia County. Mr. Folse sought “a writ to compel [the magistrate

court] to transfer a criminal appeal to [c]ircuit [c]ourt.” In the petition, Mr. Folse

represented that “[a]fter the hearing and plea agreement, [he had] filed an appeal with in

[sic] twenty days. . . . The appeal was filed with Magistrate Saundra Holepit as she was

2 Rule 20.1 of the Rules of Criminal Procedure for Magistrate Courts specifies, among other things, that an appeal from a criminal conviction in magistrate court to circuit court must be filed within twenty days after sentencing. 3 Mr. Folse did not include the State’s response to his motion to dismiss in the appendix record. Although the State noted that omission, it did not supplement the appendix to include the brief. Instead, the State elected to rely on the description of its arguments in opposition to the motion to dismiss contained in its response to Mr. Folse’s petition for mandamus relief to the Circuit Court of Monongalia County. 4 According to Mr. Folse, “no order apparently resulted from the hearing” on his motion to dismiss. The State contends that the magistrate court denied Mr. Folse’s motion and cites to two pages in the appendix record for support. The first citation leads to the magistrate court case docket, which reflects a hearing on or about March 2, 2021, but does not reflect entry of an order on Mr. Folse’s motion following that hearing. The second citation leads to page 7 of the State’s brief in response to Mr.

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