The following excerpt is from U.S. v. Harden, 846 F.2d 1229 (9th Cir. 1988):
Harden next argues, as he did in his sentencing memorandum, that for purposes of the penalty enhancement provision of section 1202(a), his three prior robbery convictions should be viewed as a single conviction. Harden's assertion is disposed of by this court's recent decision in United States v. Wicks, 833 F.2d 192 (9th Cir.1987). Harden had three prior robbery convictions based on three separate, distinct robberies. The fact that he pled guilty to them on the same date makes no difference, for, as we stated in Wicks, the requirement for the predicate convictions under section 1202(a) is satisfied by any "three predicate convictions, whenever obtained." Id. at 193 (emphasis added).
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