State v. Jacob Richard Beyer

Summary

The Wisconsin Supreme Court held that a proceeding in which the defendant stipulated to all facts establishing guilt and stipulated to a finding of guilt was not a trial, but was functionally equivalent to a guilty plea. Because Wisconsin law does not permit conditional guilty pleas of this kind, the court held that the procedure was invalid and that the defendant could not be bound by the stipulation. The court reversed and remanded for the defendant to choose whether to enter a plea or proceed to trial.

Holdings

1. A proceeding in which the parties stipulate to every fact necessary for conviction and stipulate to the defendant's guilt, leaving the court only to enter judgment and impose punishment, is more akin to a guilty plea than a trial, regardless of the proceeding's label.
2. Wisconsin does not permit a procedure in which the parties stipulate to every fact establishing the defendant's guilt and also stipulate that the court find the defendant guilty. Such a procedure is, in substance, an attempt to use a conditional guilty plea, which Wisconsin law does not authorize generally.
3. Beyer could not be held to the stipulation because he entered it in reliance on a procedure that was legally invalid. On remand, he must be permitted to choose whether to enter a plea or proceed to trial.

Questions Presented

1. Whether a proceeding in which the defendant stipulates to every fact necessary for conviction and agrees to a judicial finding of guilt is a trial or the functional equivalent of a guilty plea.
2. Whether Wisconsin law permits a stipulated trial based on stipulated facts and a stipulated finding of guilt.
3. Whether Beyer may be held to the stipulation after entering it in reliance on the invalid procedure.
4. Whether the guilty-plea-waiver rule applies to the procedure.

Disposition

reversed_and_remanded