tions or "strikes." Id. at 179. Under the law, only "serious" or "violent" felonies, as defined in California Penal Code � 1192.7(c) and � 667.5(c) respectively, qualify as prior strikes. Cal. Penal Code �� 667(d)(1), 1170.12(b)(1). The "triggering" (i.e., principal) offense, however, may be any felony under California law. Cervera, 16 P.3d at 177 ("the Three Strikes law governs when a defendant is convicted of a felony or `strike' of any kind") (emphasis added). This includes a socalled "wobbler" offense (which can be either a misdemeanor or felony) when charged and sentenced as a felony. People v. Terry, 54 Cal. Rptr. 2d 769, 770-71 (Ct. App. 1996) (holding that the wobbler offense of petty theft with a prior, when charged and sentenced as a felony, may count as a third strike).

Under the "second-strike" provision of the Three Strikes law, when a defendant with one prior strike is convicted of any felony, the sentencing court must impose a sentence twice as long as the sentence the defendant would have otherwise received. Cal. Penal Code �� 667(e)(1), 1170.12(c)(1); Cervera, 16 P.3d at 177. When a defendant with two prior strikes is convicted of any felony, the "third-strike" provision mandates a sentence of at least 25 years to life (i.e., an indeterminate life sentence with eligibility for parole after serving no fewer than 25 years). Cal. Penal Code �� 667(e)(2)(A), 1170.12(c)(2)(A).

In addition to the fact that the triggering felony need not be "serious" or "violent," several other features of California's Three Strikes law combine to make it particularly severe. First, a defendant may be considered to have two prior strikes even though he was convicted of both qualifying offenses in a single judicial proceeding. People v. Askey , 56 Cal. Rptr. 2d 782, 785 (Ct. App. 1996). Second, prior strikes need not be violent offenses as long as they qualify as "serious" (e.g., a residential burglary where the burglar was unarmed and residents were not home would be considered a prior strike). Cal. Penal Code �� 1192.7(c)(18), 460(a). Third,"serious" or "vi-

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