The March 7, 2000, adoption of Proposition 21 modified the decision in People v. Rodriquez (1998) 17 Cal.4th 253, which previously held that an abstract of judgment showing simply a conviction for violation of Penal Code section 245, subdivision (a)(1) was not sufficient evidence that the defendant had previously been convicted of a serious felony. Since Proposition 21, personal use of a deadly weapon, is no longer required, and thus an abstract stating “ASSLT GBI W/DL WPN” was sufficient.
Case Summaries