What is the test for overturning a conviction under section 1385 of the California Three Strikes Act?

A trial court's section 1385 ruling is "subject to review under the deferential abuse of discretion standard." (People v. Carmony ( 2004) 33 Cal.4th 367, 374.) "In reviewing for abuse of discretion, [an appellate court must be] guided by two fundamental precepts." (Id. at p. 376.) "First, '"[t]he burden is on the party attacking the sentence to clearly show that the sentencing decision was irrational or arbitrary."'" (Ibid.) "Second, a '"decision will not be reversed merely because reasonable people might disagree."'" (Id. at p. 377.) Because the Three Strikes law "creates a strong presumption that any sentence that conforms to [its] sentencing norms is both rational and proper," a trial court's decision not to strike a prior conviction will generally be upheld. (Id. at p. 378.) Abuse of discretion for failure to strike occurs only in "limited circumstances," such as where the trial court was unaware of its discretion or "considered impermissible factors" or in an "extraordinary case . . . where the relevant factors . . . manifestly support the striking of a prior conviction and no reasonable minds could differ . . . ." (Ibid.)