How have courts interpreted section 273.5(e)(1) of the California Criminal Code?

⁴ Interpreting an ambiguous record in the course of concluding that the trial court imposed an unauthorized sentence, People v. Price (2004) 120 Cal.App.4th 224, 242, 15 Cal.Rptr.3d 229, described section 273.5(e)(1) as an "offense" that "include[es] the element of a prior conviction" (italics omitted). As this was dicta without any thorough analysis of the proposition announced or compelling logic in its support, we do not find it persuasive. (People v. Smith (2002) 95 Cal.App.4th 283, 300, 115 Cal.Rptr.2d 483.)

^** See footnote *, ante .