Out-of-state convictions can be considered sexually violent offenses warranting prison prior enhancements under PC 667.5(b), even after changes in the law under PC 1172.75. PC 1172.75(a) makes invalid any sentence enhancement imposed prior to January 2020, pursuant to PC 667.5(b), except for an enhancement imposed for a sexually violent offense as defined in WIC 6600(b). The court concludes that a PC 667.5(b) enhancement based on a prior conviction in another jurisdiction for an offense that includes all of the elements of an offense described in WIC 6600(b) remains valid.

The full opinion is available on the court’s website here: https://www4.courts.ca.gov/opinions/documents/E082997.PDF