Does section 1192.7(c)(18) of the California Criminal Code include a sentence enhancement for repeat offenders who commit serious felonies?

In June 1982, the voters adopted section 1192.7(c)(18) as part of Proposition 8. That initiative enacted sections 667 and 1192.7 to provide for a sentence enhancement for repeat offenders who commit "serious felonies" as enumerated in section 1192.7. (People v. Jackson (1985) 37 Cal.3d 826, 830, 210 Cal.Rptr. 623, 694 P.2d 736.) Although most of the "serious felonies" listed in section 1192.7 referred to specific, defined criminal offenses, section 1192.7(c)(18), as originally enacted by the electorate, did not. Rather, as enacted, it listed as a serious felony "burglary of a residence," a term we noted "does not correspond precisely to the elements of any then-existing criminal offense." (People v. Jackson, supra, 37 Cal.3d at p. 832, 210 Cal.Rptr. 623, 694 P.2d 736.)