Nichols v. United States
United States Supreme Court
511 U.S. 738 (1994)
Relevant factsFree
Nichols (defendant) was convicted of a federal drug offense, and the sentencing court used his earlier state DUI misdemeanor conviction — for which he received only a fine and no jail time, and for which he had no attorney — to enhance his sentence on the drug charge. Nichols argued the enhancement was improper because the DUI conviction was uncounseled.
IssueFree
Whether a prior misdemeanor conviction obtained without counsel, but which resulted in no term of imprisonment, may be used to enhance a prison sentence imposed for a later, counseled conviction.