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Name: People v. Tillotson
Case #: G035041
Court: CA Court of Appeal
District 4 DCA
Division: 3
Opinion Date: 11/30/2007

Status enhancements are those that relate to the offender and can be imposed only once in arriving at an aggregate sentence. Status enhancements include an enhancement for a prior conviction such as Health and Safety Code section 11370.2, subdivision (c). The second type of enhancement is one which goes to the nature of the offense, such as a weapons-use enhancement.
When prison sentences are imposed on multiple secondary offenses and one primary offense, Penal Code section 12022.1, subdivision (e), requires the sentence on one secondary count to run consecutively to the sentence on the primary count; but whether the sentences on the secondary counts are consecutive or concurrent to each other is within the trial court’s discretion.