What is the test for proving a sentence enhancement?

California, United States of America


The following excerpt is from People v. Daniels, F064237 (Cal. App. 2014):

"The People must prove all elements of an alleged sentence enhancement beyond a reasonable doubt." (People v. Miles (2008) 43 Cal.4th 1074, 1082.) Certified documents from the record of prior proceedings may be used to prove a prior conviction allegation. (Id. at p. 1082.) "[T]he trier of fact may draw reasonable inferences from the record presented." (Id. at p. 1083.) Unless the document is rebutted, "such a document, standing alone, is sufficient evidence of the facts it recites about the nature and circumstances of the prior conviction. [Citation.]" (Ibid.)

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