People v. Williams

Summary

The California Supreme Court held that Penal Code section 667(a) five-year enhancements for prior serious felony convictions may be applied individually to each count of a third-strike sentence. The court concluded that the determinate-sentencing limitation recognized in People v. Tassell does not apply to multiple indeterminate life sentences under the Three Strikes law and affirmed the judgment.

Holdings

1. Penal Code section 1170.1 applies to determinate sentences and does not govern sentencing calculations for multiple indeterminate life terms imposed under the Three Strikes law.
2. Under the Three Strikes law, a Penal Code section 667(a) five-year enhancement for a prior serious felony conviction must be applied individually to each count of a third-strike sentence and may be imposed even if the same prior convictions previously enhanced a sentence in a separate case.

Questions Presented

1. Whether Penal Code section 1170.1 limits the imposition of Penal Code section 667(a) prior-serious-felony enhancements to one application when a defendant receives multiple indeterminate third-strike sentences.
2. Whether the same prior serious felony convictions may support section 667(a) five-year enhancements imposed separately for each new serious felony conviction under the Three Strikes law, even when those prior convictions were previously used to impose enhancements in a separate case.

Disposition

affirmed