California, United States of America
The following excerpt is from People v. Phariss, F073809 (Cal. App. 2018):
The case of People v. Neely (2009) 176 Cal.App.4th 787 (Neely), cited by Phariss, does not stand for the proposition that section 1170.1 applies to separate cases that are sentenced separately, but ordered to run concurrently. For section 1170.1 to apply, Neely recognizes that at least one felony term must run consecutive to some other felony term. (Neely, supra, 176 Cal.App.4th at pp. 797-799.)
Section 669, subdivision (a) also does not mandate an aggregate sentence. Section 669, subdivision (a) provides in relevant part:
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