California, United States of America
The following excerpt is from People v. Rojas, 206 Cal.App.3d 795, 253 Cal.Rptr. 786 (Cal. App. 1988):
Nevertheless, respondent argues that nowhere in section 667 is there a provision that the prior conviction must have been entered before the commission of the present offense. According to respondent, the defendant need only to have been convicted of the prior offense before he is [206 Cal.App.3d 801] convicted of the present offense. Additionally, respondent persists, since "conviction" has been interpreted to mean the verdict of guilt rather than the judgment (see, e.g., People v. Clapp (1944) 67 Cal.App.2d 197, 200, 153 P.2d 758), appellant was "convicted" of the prior offense before he was convicted on the instant offense.
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