California, United States of America
The following excerpt is from People v. Williams, E072253 (Cal. App. 2020):
We offered defendant an opportunity to file a personal supplemental brief, and we offered both parties an opportunity to file supplemental briefing regarding the one-year prior felony convictions. No supplemental briefs were filed. Pursuant to the mandate of People v. Kelly (2006) 40 Cal.4th 106, we have independently reviewed the record for potential error and find no arguable issues.
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