California, United States of America
The following excerpt is from People v. Robinson, E065044 (Cal. App. 2017):
3. Defendant never personally and expressly waived his right to a jury trial on the prior conviction allegations. However, he has not claimed this was error. And wisely so; he forfeited any such claim by failing to raise it below. (People v. Vera (1997) 15 Cal.4th 269, 276-278.)
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