What is the test for proving a prior conviction?

California, United States of America


The following excerpt is from People v. Alston, E055052 (Cal. App. 2013):

Normally, proving the fact and nature of a prior conviction is done by introducing "certified documents from the record of the prior court proceeding and commitment to prison, including the abstract of judgment describing the prior offense." (People v. Delgado (2008) 43 Cal.4th 1059, 1066.) "'[The] trier of fact is entitled to draw reasonable inferences from certified records offered to prove a defendant suffered a prior conviction. . . .' [Citations.] '[Official government records clearly describing a prior conviction presumptively establish that the conviction in fact occurred, assuming those records meet the threshold standards of admissibility. (See Evid. Code, 664 ["It is presumed that official duty has been regularly performed"].) Some evidence must rebut

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