Drum wanted to go to drug court. To get there, he had to stipulate to all of the evidentiary issues. It took 42 days to get him a bed in rehab, and he decided he just wanted to get it over with, and opt out of the program. The trial court wouldn’t let him argue the evidentiary issues.
The court of appeals held that the stipulation essentially waived a right to be found guilty beyond a reasonable doubt because the contract said that Drum was admitting the sufficiency of the evidence for conviction. However, sufficient to convict is a much lower burden than reasonable doubt:
We are troubled by the Court of Appeals’ suggestion that a drug court contract clause stipulating to the sufficiency of the evidence results in the defendant waiving his right to a determination of guilt beyond a reasonable doubt. Such a clause would have no place in a drug court contract, and the Court of Appeals erred in reading the clause in Drum’s Contract so broadly. Instead, the trial court correctly interpreted the Contract to provide that the defendant stipulates to a set of facts and, based on these facts, there is sufficient evidence to establish guilt. By entering a drug court contract, a defendant is not giving up his right to an independent finding of guilt beyond a reasonable doubt. A trial court still has the authority to find the defendant not guilty if it determines that the stipulated evidence does not establish all elements of the crime beyond a reasonable doubt.
However, the trial court here did make a finding based on the evidence, and that evidence was sufficient per the supreme court.
