California, United States of America
The following excerpt is from People v. Ward, 188 Cal.App.3d 459, 233 Cal.Rptr. 477 (Cal. App. 1986):
As with the previous issue, we have the benefit of our high court's recent thinking on this question in People v. Pearson, supra. Although it recognized that the issue appeared premature, the Pearson court considered the appellant's request that they prohibit the use of more than one conviction based on each criminal act for the purpose of enhancing any subsequent sentences he may receive. The court concluded:
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