Paul Misenhelter, Petitioner v. the People of the State of Colorado, Respondent

Summary

The court held that a conviction arising from the same proceeding as the offense being sentenced may qualify as a prior-conviction exception to the jury-trial requirement if it was entered through constitutionally proper procedures before sentencing. Because Misenhelter knowingly, intelligently, and voluntarily pleaded guilty to aggravated incest before being sentenced for negligent child abuse, the trial court could consider that conviction and its elements in imposing an aggravated sentence. The court therefore affirmed the court of appeals.