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Name: People v. Henkel
Case #: A096715
District 1 DCA
Division: 2
Opinion Date: 05/02/2002
Subsequent History: None

Here, Division 2 of the First District Court of Appeal follows the trend set by the Second District (Division 5) and the Fourth District (Division 2) in holding that based on the language of the statute as well as legislative history, the five-year “washout” period required by Proposition 36 refers to the five-year period immediately preceding the commission of the current offense.