Wilson v. Knowles

In 1993, Rick Wilson (defendant) pleaded no contest in California state court to (1) gross vehicular manslaughter while driving under the influence of alcohol (DUI) under the California Penal Code and (2) proximately causing bodily injury while DUI under the California Vehicle Code. Both convictions resulted from the same accident; Wilson was drunkenly speeding and lost control of his girlfriend’s car, injuring his girlfriend and killing another passenger. Wilson had a preliminary hearing but no trial, and Wilson was incarcerated for a year at an addiction-treatment residence. In 2000, a jury convicted Wilson of DUI with a prior felony conviction. The trial court counted the 1993 convictions as Wilson’s first and second strikes, based in part on the prosecution’s evidence about the alleged facts of the 1993 case. Although the court found that in the 1993 accident, Wilson had personally inflicted great bodily injury on a victim who was not an accomplice, those findings were not elements required to support Wilson’s conviction for the 1993 California Vehicle Code offense. Concluding that the 2000 offense was a third-strike offense, the court sentenced Wilson to 25 years to life in prison. Wilson exhausted his state court appeals, then filed a habeas corpus petition in federal district court, contesting his third-strike sentence. The district court denied Wilson’s petition. Wilson appealed to the United States Court of Appeals for the Ninth Circuit.