Supreme Court of Missouri / Feb 24, 2026
citedCitation: Erlinger v. United States, 602 U.S. 821
James Willis Peters appealed his conviction for driving while intoxicated as a chronic offender, challenging whether the state proved beyond a reasonable doubt that all four of his prior offenses were intoxication-related traffic offenses. The court found the state failed to sufficiently prove his 2002 offense was an IRTO and therefore vacated the judgment and remanded for resentencing.
Supreme Court of Missouri / Jan 13, 2026
followedCitation: Erlinger v. United States, 602 U.S. 821
The Missouri Supreme Court upheld section 577.023.2, which allows circuit courts rather than juries to determine whether prior DWI convictions occurred on separate occasions for purposes of charging a persistent offender felony. The court rejected the defendant's argument that this procedure facially violates the Fifth and Sixth Amendments, finding the statute constitutional and that the circuit court lacked authority to dismiss the felony charge.
Missouri Court of Appeals, Eastern District / Sep 23, 2025
distinguishedCitation: Erlinger v. United States, 602 U.S. 821
Missouri Court of Appeals, Eastern District / Jul 15, 2025
citedCitation: Erlinger v. United States,
602 U.S. 821
Missouri Court of Appeals, Eastern District / Date unavailable
citedCitation: Erlinger v. United States, 602 U.S. 821
Missouri Court of Appeals, Eastern District / Date unavailable
followedCitation: Erlinger v. United States,
602 U.S. 821
Missouri Court of Appeals, Western District / Date unavailable
followedCitation: Erlinger v. United States, 602 U.S. 821