California, United States of America
The following excerpt is from People v. Santana, 182 Cal.App.3d 185, 227 Cal.Rptr. 51 (Cal. App. 1986):
The practice of using a 667, subdivision (a) serious prior felony conviction as a factor in aggravation was addressed in our opinion in People v. Keys (1985) 175 Cal.App.3d 431, 220 Cal.Rptr. 760.
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