WIGGINS, Justice.
The district court held the State could not use an uncounseled guilty plea to a prior misdemeanor to enhance a subsequent offense to operating while intoxicated (OWI), third offense where the court imposed incarceration as part of its sentence on the prior offense without an in-court colloquy. Our court of appeals reversed the district court's ruling. Because the defendant's written guilty plea in the prior proceeding met the requirements of the...
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