Does a prior conviction enhancement for on-bail constitute an abuse of discretion?

considering the parties' arguments, it ultimately found that the enhancement, although not itself a prior conviction, "was discussed in terms of those prior convictions," the determination of which was bifurcated. This ruling constitutes an abuse of discretion only if it "'falls outside the bounds of reason.'" (People v. Osband (1996) 13 Cal.4th 622, 666; see People v. Franklin, supra, 248 Cal.App.4th at p. 952.) We conclude that it does not.

Defendant waived his right to a jury trial in this case and, therefore, the common concern regarding the risk of causing a defendant undue prejudice before the jury was not at play. Nevertheless, the parties agreed to bifurcate the truth of defendant's prior convictions and, like a prior conviction enhancement, "a section 12022.1 enhancement turns on the status of a defendant as a repeat offender, not on what the defendant did when committing the current crime ...." (People v. Walker (2002) 29 Cal.4th 577, 589.) The "enhancement does not punish a defendant for his or her conduct while committing an offense ..., but rather punishes the defendant for his or her status as a repeat offender while on bail ...." (Ibid.) Because proving the on-bail enhancement allegation, like proving the prior conviction enhancement allegations, was not connected to proving the charged offenses, the trial court could have reasonably concluded that although it used the term "prior convictions" at times, the on-bail enhancement allegation was intended to be included within the group of bifurcated prior conviction enhancement allegations.