State v. Drum

Summary

The Washington Supreme Court held that a defendant’s stipulation in a drug court contract concerning the sufficiency of the evidence was not binding on the trial or appellate courts. The court independently reviewed the stipulated evidence and concluded that it was sufficient to support Drum’s residential burglary conviction. It also held that the statutory inference of criminal intent under RCW 9A.52.040 operated permissibly in this case and did not create an unconstitutional mandatory presumption.

Holdings

1. A defendant's stipulation to the legal sufficiency of the evidence in a drug court contract does not bind the trial court or the Court of Appeals. The court must independently determine whether the evidence proves guilt beyond a reasonable doubt.
2. The evidence was sufficient to sustain Drum's residential burglary conviction.
3. As applied in Drum's case, RCW 9A.52.040 operated as a permissive inference rather than an unconstitutional mandatory presumption and did not shift the burden of proof.
4. The drug court contract was not equivalent to a guilty plea and did not require the due process protections applicable to guilty pleas.

Questions Presented

1. Whether a criminal defendant's stipulation in a drug court contract that the evidence is sufficient to establish guilt binds the trial court or appellate court.
2. Whether the evidence was sufficient to prove Drum's criminal intent for residential burglary.
3. Whether RCW 9A.52.040 created an unconstitutional mandatory presumption or shifted the burden of proof to Drum.
4. Whether Drum's drug court contract was tantamount to a guilty plea and therefore required the due process protections applicable to guilty pleas.

Disposition

affirmed