California, United States of America
The following excerpt is from People v. Deay, 194 Cal.App.3d 280, 239 Cal.Rptr. 406 (Cal. App. 1987):
In People v. Wilks (1978) 21 Cal.3d 460, 146 Cal.Rptr. 364, 578 P.2d 1369, the defendant was found to have suffered four prior convictions within the meaning of former section 3024, subdivision (c), which provided a minimum prison term for those previously convicted of a felony. The defendant contended that only two prior convictions should have been found because three of the prior convictions resulted from a single, multi-count information. The court rejected his contention, reasoning that under former section 3024, subdivision (c), it was immaterial how many prior convictions were suffered; one would suffice. The court also suggested, however, that the result may have been different had the defendant been adjudged an habitual criminal under former section 644 on the basis of multiple prior convictions "separately brought and tried." (21 Cal.3d at pp. 469-470, fn. 9, 146 Cal.Rptr. 364, 578 P.2d 1369.)
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