How have courts interpreted the meaning of section 995 of the "three strikes" law?

We note that the trial court should not have reached the brought and tried separately issue on Arevalos's section 995 motion as the People were not required to prove the prior convictions at the preliminary hearing. (Miranda v. Superior Court (People) (1995) 38 Cal.App.4th 902, 45 Cal.Rptr.2d 498.) Nevertheless, we address the merits of the People's contention concerning the validity of the prior convictions for the trial court's guidance.

" ' "We begin with the fundamental rule that our primary task [in construing a statute] is to determine the lawmakers' intent. [Citation.] ... To determine intent, ' "The court turns first to the words themselves for the answer." ' [Citations.] If the language is clear and unambiguous there is no [41 Cal.App.4th 912] need for construction, nor is it necessary to resort to indicia of the intent of the [lawmakers].... [Citation.] Words used in a statute ... should be given the meaning they bear in ordinary use. [Citation.] We are not prohibited from determining whether the literal meaning of a statute comports with its purpose or whether such a construction of one provision is consistent with other provisions of the statute. The meaning of a statute may not be determined from a single word or sentence; the words must be construed in context, and provisions relating to the same subject matter must be harmonized to the extent possible. [Citation.] Literal construction should not prevail if it is contrary to the legislative intent apparent in the [statute.] [Citation.] The intent prevails over the letter, and the letter will, if possible, be so read as to conform to the spirit of the act. [Citations.] An interpretation that renders related provisions nugatory must be avoided [citation]; each sentence must be read not in isolation but in light of the statutory scheme...." (People v. Ramirez (1995) 33 Cal.App.4th 559, 563, 39 Cal.Rptr.2d 374, internal quotation marks omitted.) "The rule of the common law, that penal statutes are to be strictly construed, has no application to this code. All its provisions are to be construed according to the fair import of their terms, with a view to effect its objects and to promote justice." ( 4.)

Section 667, subdivision (a)(1), which is not part of the "three strikes" law, states: