What is the test for adding "extra fact" to the facts of a prior conviction for the same crime?

The trial court disagreed with defendant's argument, and so do we. As the trial court stated, "To make an 'extra fact' determination regarding a prior conviction in order to find that it constitutes a 'serious felony' for enhancement purposes, a trial court may examine the record of conviction, including a summary of evidence recited in any appellate opinion rendered in the matter (see People v. Woodell (1998) 17 Cal.4th 448). The same principles should apply in the Penal Code 1170.126 resentencing context."