How has section 17 of the California Code of Criminal Procedure been interpreted in the context of criminal history?

People v. Park illustrates this principle. There, the defendant was convicted of a felony in 2003. The trial court suspended imposition of sentence and placed him on probation. In 2006 the court reduced the conviction to a misdemeanor pursuant to section 17, subdivision (b)(3). (People v. Park, supra, 56 Cal.4th at p. 787.) When the defendant was convicted in 2007 of a new felony, the court imposed a five-year serious felony enhancement pursuant to section 667, subdivision (a), predicated on the 2003 felony conviction. (People v. Park, supra, at pp. 787-788.) Construing section 17's

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