California, United States of America
The following excerpt is from People v. Mackey, 2d Crim. No. B295661 (Cal. App. 2020):
offender; and (2) those which go to the nature of the offense. Enhancements for prior convictions . . . are of the first sort. . . . Enhancements of the second kind enhance the several counts; those of the first kind, by contrast, have nothing to do with particular counts but, since they are related to the offender, are added only once as a step in arriving at the aggregate sentence." (People v. Tassell (1984) 36 Cal.3d 77, 90, overruled on another ground in People v. Ewoldt (1994) 7 Cal.4th 380, 401.)
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