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Name: People v. Laino
Case #: S103324
Court: CA Supreme Court
District CalSup
Opinion Date: 04/08/2004

The full faith and credit clause does not bar California from deciding whether a guilty plea in another jurisdiction constitutes a conviction for purposes of California’s three strikes law. The defendant here pled guilty to an aggravated assault with a handgun in Arizona, but successfully completed a domestic violence diversion program resulting in a judgment of dismissal of the charges. The Arizona case was nonetheless used to enhance a subsequent sentence in California. On appeal, the defendant argued that California was constitutionally barred from determining that the Arizona case constituted a prior conviction, but the Supreme Court held that, given a state’s legitimate interest in enforcing its own penal laws against people who commit crimes within its borders, the full faith and credit clause does not bar a state from determining the meaning of “conviction” for purposes of prior conviction enhancements. The court further held that the Arizona conviction constituted a strike under California law, because the Arizona proceedings were not akin to California’s deferred entry of judgment scheme, which do not include domestic violence felonies.