Does a guilty plea constitute a conviction within the meaning of section 667?

6 In People v. Lobaugh (1987) 188 Cal.App.3d 780, at pages 784-785, 233 Cal.Rptr. 683, this court followed Flint 's holding in rejecting the contention that a guilty plea does not constitute a conviction within the meaning of section 667. In so doing, however, we unfortunately recited Flint 's dictum, which we now reject.

We also reject any suggestion that separateness for purposes of applying section 667 may be measured by some sort of section 654 analysis, viz, whether or not the offenses underlying the multiple prior convictions at issue were committed during an indivisible course of conduct and incident to a single intent and objective. (See Neal v. State of California (1960) 55 Cal.2d 11, 19, 9 Cal.Rptr. 607, 357 P.2d 839.) Not only does this type of analysis add superfluous language and meaning to section 667, it approves punishment under section 667 commensurate with a defendant's culpability for his prior offenses, not for his culpability as a recidivist. As such, it flies in the face of section 667's purpose, not to mention constitutional limitations upon section 667's application. (See People v. Jackson (1985) 37 Cal.3d 826, 833, 210 Cal.Rptr. 623, 694 P.2d 736.)