When the underlying base sentence already exceeds 20 years, PC 1385(c)(2)(C) does not weigh in favor of the dismissal of an enhancement, because the enhancement itself must cause the sentence to exceed 20 years to qualify. Based on the plain language of the statute, the court disagreed with defendant’s argument that subdivision (c)(2)(C) applies whenever an enhancement is a component of a sentence that exceeds 20 years. [Editor’s Note: To forestall appellant’s claim of ineffective assistance of counsel, the court reached the merits of the claim despite the lack of an objection.]

The full opinion is available here: http://www4.courts.ca.gov/opinions/documents/C100501.PDF