California, United States of America
The following excerpt is from People v. Bright, 12 Cal.4th 652, 49 Cal.Rptr.2d 732, 909 P.2d 1354 (Cal. 1996):
3 The 1923 amendment was passed, at least in part, in response to cases attempting to determine the appropriate sentence under section 664 for a crime punishable by an indeterminate sentence of life imprisonment. (See People v. Sama (1922) 189 Cal. 153, 207 P. 893 [holding that imposition of a punishment of one-half of a sentence of life imprisonment for the crime of attempted robbery would be invalid].)
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