Brown v. Multnomah County District Court
Oregon Supreme Court
570 P.2d 52 (1977)
- Written by Angela Patrick, JD
Facts
Under the Oregon state vehicle code, traffic offenses were classified as either infractions with civil penalties or crimes with criminal penalties. For the offense of driving while under the influence of intoxicants (DUI), the vehicle code classified a first-offense DUI as a traffic infraction carrying only civil penalties. A first-offense DUI conviction carried a possible $1,000 fine, and not paying that fine could cause the defendant to lose his driver’s license. Like other defendants charged with crimes, a DUI defendant was fingerprinted and could be detained in jail. A DUI conviction carried the same stigma as being convicted of a crime. Hugh Brown (defendant) was charged with a first-offense DUI. Brown could not afford an attorney and asked to have an attorney appointed to represent him. Brown also asked for a jury trial and to have the state prove its case beyond a reasonable doubt. The district court denied Brown’s requests. Brown appealed, arguing that he was entitled to these rights because he was facing criminal penalties that had been mislabeled as civil penalties and was, therefore, a criminal defendant. The court of appeals found that the first-offense DUI penalties were not criminal and, therefore, that Brown was not constitutionally entitled to the protections given to a criminal defendant. The Oregon Supreme Court agreed to review the issue.
Rule of Law
Issue
Holding and Reasoning (Linde, J.)
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